Section 9

LICENSING i U

FISHERIES (AMENDMENT) ACT, 1997 and

SHELLFISH AND FINFISH

Aquaculture and Foreshore Licence Application Form

Important NoteSection 4 of the Fisheries and Foreshore (Amendment) Act, 1998 (No. 54)

prohibits any person making an application on or after 10 December 1998 for an Aquaculture Licence from commencing aquaculture operations until duly licensed under the Fisheries (Amendment) Act, 1997 (No. 23), and provides that a breach of

that prohibition will cause the application to fail.

Aquaculture & Foreshore Management Division Department of Agriculture, Fisheries & Food

ClogheenClonakilty, Co. Cork

Fax: (023) 8821782

AQUACULTURE AND FORESHORE LICENSING APPLICATION FORM, for purposeso f FISHERIES (AMENDMENT) ACT. 1997 and FORESHORE ACT. 1933-

Accompanying Guidance Notes should be read before completing this form.Note: Details provided in Parts 1 and 2 will be made available for public inspection.Details provided in Part 3 are confidential and are not for public disclosure.USE BLOCK CAPITALS IN BLACK INK

Name(s) o f Applicant(s) in full:1 .A Bradan Fanad Teoranta t/a Marine Harvest Irelandl.B -

Address(es) o f Applicant(s) in full:1 .A Kindrum Please address all correspondence to:

Fanad Southwest Operations ManagerLetterkenny Marine Harvest IrelandCounty Donegal The Pier, Castletownbcre,

CRONo: 104180 Beara, County CorkTel: 07491 59071 Fax: 07491 59077 Tel: 027 70216 Fax: 027 70188

1 ,C TYPE OF APPLICATION Insert X in relevant boxIndicate the relevant type of application:-(i) Aquaculture Licence-(ii)Trial Licence-(iii)Review o f Aquaculture Licence -(iv)Renewal o f Aquaculture Licence -(v) Foreshore Licence

(This Application Form is valid for each type o f application.)1 .D TYPE OF AQUACULTURE Indicate the relevant type o f application:-(i) Land-based-(ii) Marine-based-Shellfish(iii) - extensive(iv) —'intensive

Y es

-(v) Finfish

)II

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I

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l.E DOCUMENTS ENCLOSED WITH THIS APPLICATION The following documents are enclosed with this application:(1) - Ordnance Survey Map (Scale of 1: 10,560, ie, a six inch map) OBLIGATORY(2) - British Admiralty Chart (largest available scale)

(3) - Decision of planning authority under Planning Acts

(4) - Copy of licence under Section 4 of Local GovernmentWater Pollution) Act, 1977

(5) - Environmental Impact Statement(6) - Drawing o f the structures to be used and/or the layout of the farm OBLIGATORY(7) - Water Quality Analysis Report (required for Land-based sites only)(8) - Application Fee OBLIGATORY

(9) - Other (specify): - __________________________ ________________________

Yes

YesYes

Paid

^TcT

2.A Employment, Qualifications, Experience, Etc.(i) Details of Applicant’s qualifications and experience in aquaculture:

The company is a subsidiary company o f Comhlucht Iascaireachta Fanad Teoranta (t/a Marine Harvest Ireland). The experience mthin the Marine Harvest group in Ireland in the discipline of finfish aquaculture stretches back to the foundation o f the industry in Ireland, in the 1970's, and indeed internationally. The applicant has the full financial, marketing and technical support o f the

group.

(ii) Other relevant experience (courses attended, etc);Various members o f staff attend numerous courses as required, for example in diving (HSE Part 4), Skipper's ticket, Power Boat Cert, Marine Safety, Marine Survival, VHF Cert, etc. Courses are selected as required on the basis o f the staff member's role and function within the company.

(iii) Details of projected employment creation during first four years of proposed development:It is expected that the proposed operation will result in the creation o f 8 full-time jobs, to augment the present workforce o f the company in the area o f some 3 7 full and part time jobs.

(iv) Projected employment (number of persons):Year 1: 5 Year 2: 7 Year 3: 8 Year 4: 8

I

2.B Aquaculture Site Details Indicate type o f site:

(i) Land-based(ii) Marine-based Yes

(ifcSkeich & the layout of me sire in relation to the river(s), ro?!d(skaad tmiidiugs:(ii) Water quality Analysis Report, which should be dratynuqfmaccordance with the parameters

set out if Aum. C of the Guidtagce N otes._--—2.E The :.v !ng conedtiont-mri?; be met in -order to fliov. foi consideration of licensing of laud-based acjyscaMre:- (i) thejiiwhimgs and equipment must be put in place to the Department's,sal is tact ion; an —fflfthe operation must comply with Local Authority requirements.2JLMariac-l^sediil6(53t(To be completed if appropriate) Location -(i) Bay: Bandy Bay

-(ii) County: County Cork(ii) OS Map No: Discovery Series 1:50,000. Map 85; also OS 6 Inch Series Sheets CK116 / CK 117.

(iii) Site Co-ordinates:

WGS 84 Iristi GridS Latitude Longitude I Eastinqs Northings|NW comer i 51° 40.255'N -9“ 39 980‘ W 84737 47798NE corner I 5V 40.394’ N -9' 39 234' W 85567 47980|SE corner 51’ 40.103'N -9“ 39.181'W 85675 47492BtW cornere 5 r 39.993' N

§jjw 84845 47308'Site centre ! 51° 40.179' N -9“ 39.571' W 85206 47644

(iv) Size of site (hectares): 850m x 500m = 4011a(v) Species (common and scientific name): Atlantic salmon; Salmo salar(vi) Method of culture (e.g., nets, ropes, tanks, trestles, etc.) Circular net pens(vii) Drawings of structures to be used in method of culture should be enclosed. Enclosed(viii) If cages or tanks are proposed, state: Cages-(a) Number: For a 24 month growth cycle (November Year 1 to October Year 2); twelve cages fo r

Months 1 to 15, temporarily rising to a maximum o f fourteen cages during biennial grading / han’estingfor 4 months between Months 16 to 20 (February to June o f year 2 o f cycle). Site fallow fo r up to 2 months biennially between Months 23 and 24, before restocking. Site includes mooring o f feed barge, centre inshore o f mooring grid.

-(b) Type and shape: Plastic frame (stanchions, rails and galvanised steel reinforced triple-pipe floatation collar), circular, 128m circumference (approx 40.8m diameter).

-(c) Cubic capacity: 19,600m3 per cage - total 12-cage volume o f approx 240,000m3 during growth phase, rising to a peak of280,000m3, fo r maximum o f four months; between February and June in year two o f each 24-month cycle, fo r grading and harvesting.

-(d) Depth: 15m to mid-centre o f bottom net(ix) Proposed specific site locations (with reasons): This site was selected due to its good water exchange

and depth. The nearest licensedfinfish farm site is 5,000m away (centre to centre) to the SE. Visibility is generally obscured from easily accessible terrestrial vantage points in the area. The site is close to the shelter o f Trafrask and Adrigole Harbours, fo r safe small boat mooring and access. The site is also 8.25km from the company's Roancarrig site and close to Castletownbere (17.7km) fo r harbouring o f larger work boats and well boat.

(x) Describe proposed purification facilities to be used, where appropriate: - None

Marine-based Suets') (continued')2.G Give details o f any special requirements relating to the health o f the proposed project

and the wider matters of public health and safety:For the safety o f passing vessels, it is proposed to fit a yellow flashing light to each corner o f the mooring system. Radar reflectors will also be fitted on all corner cages and on the centre cages on the long sides o f the cage formation. A navigation buoy with flashing light, yellow St Andrew's cross and radar reflector mil also be moored to the SE and SW corner anchors. Proposed specification for all lights is SL 4sec with 3-mile range; see diagrams appended. Proposed navigational aids may be modified, consistent with the specific requirements for the site, as set down in the terms o f the Aquaculture Licence, as advised by the Marine Survey Office and the Commissioners for Irish Lights. All health and safety matters on Marine Harvest sites are policed by the MHI Health and Safety Officer and by the surveyors o f the company's insurance brokers, Sunderland Marine.

2.H Tonnage to be produced:Species Year 1: Year 2: Year 3: Year 4:(To state)Salmo Salar OTonnes 3,500Tonnes OTonnes 3,500Tonnes2.1 Reasons for selection of site:

The site was selected on the basis o f studies into the local geography, topography, hydrography, wave climate and water depth, the distribution o f other aquaculture licences, the distribution o f other stakeholder activities and the visual impact o f the proposed structures on the locality. Of the candidate sites remaining in Banlry Bay that could be deemed satisfactory in respect o f this range of characteristics, it is submitted that the area selected, to the east o f Shot Head, is the most suitable.Note: The proposed access route to the site(s) from public road across tidal foreshore area Must be indicated on the OS map accompanying the application.No access route across the tidal foreshore will be required by the company. However the company will wish to use the following piers for movements of vessels to and from the site: Main piers; Castletownbere Harbour Area (up to daily), Beal Lough Pier (the Pontoon; 2-3 times per 'week); subsidiary piers; Adrigole Pier and Trafrask Pier (tidal); (infrequently; small vessels e.g. workboats and small tenders only) _____

2.J Environmental Impact Statement tElST

A copy o f an EIS, i f required, should be enclosed with the application. The EIS should contain the information specified in Annex B o f the Guidance Notes. Enclosed with application._____________

CQNFIDENTIAL

1. Cost o f project (total capital and current costs as at 7 and 8 below)

2. How will this project be financed (own resources and any other sources)? ^ (i,e. own resources).

3. Will this project be your only source of employment/ income?

5. Do you intend to apply for grant aid or other funding from any State source (BIM, Udaras na Gaeltachta, FORFAS, etc.)? N/A

6. If yes, g m detai

7. Proposed capital costs of project:Item

Fish PensComplete grid moorhrg system

Grower Bird nets Smolt bird nets j - % A f i | |

Net weights fS&y'lir’ -r . ■ ti . .. ■ ... ‘?r£<'it|Black tender boat including out board engines

Feed Barge, mooring system and feed pipes and spreaders

Work boatN avigation buoys, lights and radar reflectors

Lift up system for Mort removal Life rafts, cameras and compressor hire

Gfest €

Iw*

5

H. Proposed non-capital costs of project (ieseed, fsed, labour, etc.):

Item per ‘T w o year cycle” Cost €Smolts M l S * * M —

Fish feed W M m t __________Labour -:A- **§11?'

W ell boat leasing, including harvest transferNet maintenance m 1 M m I

D iving costs i -f..

«m$k If -

Boat HireStaff train ing _--—-— —

Boat MaintenanceM ooring Maintenance

Fish processing _______.,_ •>•-.___.... ..._ — - •

-— --- —- -------- ---------" ' *

9. Provide an estimatfrsf tiifc value o f production over the first four year's based cm projected ton.) ige:

iO ilow many years from the star! of die project v/iil ii be before you “break even”, i.e. vour

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i Wc hereby declare the information rev-, idc4in Parts I. - and 3 above to be trueIC .f!C ],c>! Vv; m* »Hir knowledge CVi e enclose an application fee* of ( Note Tee cent under separate iTyfl*

FOfr. A HD DA1.&LH&LF O f &H.f\QKM

F fin r \o u o r M 7 A . C r / fi M M w a $ £ l u \ h d )

Date q O - ___2 0 t t »* Preferred method of payment is by cheque or hank draff T he fee should be made payable to the Department ol Agriculture, fisheries and food,

rhts form slHHtld be fbrvvardctL with the required documents and application fee, to;Aquaculture 1 .iccnsingAquaculture & Foresluuc Management Division (. loghecti Cionakilty.( o. Cork “* ^ A~

Application fo r a saimon farm site at Sh Head, Bantry Bay, County Cork Proposed Qoa -jrai:sod cage and farm layout and specification diagram.i Jot? cage grid area §.88hs (420m >: 140rn'i .cage rings end grid are to scale, grid buoys, moorings and anchors are dfeigramnnift; nn%.

nComer grid buoy.

Studlink I anchor chain

Centre grid buoy

Lateral grid buoy. Grid width 140m t

■fir:'

Srid length 420m

x

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anchor

Cage ring. Mooring rope.

Grid rope. Lateral mooring.

End (axial) anchor A X /

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1 Oj CL- W: £;• & J§ 1

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5«r • M - Cop yJ-'-’ «Tnoonnos ^ p precto rn&K ' '

, . , B ay. c o u n ty CO..'ead. Ban '> av m arks,

i f .c a t io n c lia g '^ ; '; ,_ j rtfiO ciinnesp01* ^

riocuro^nrt CG of apP,ical1° n1 /

aredinc

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Comer grid buoy^

’7 /

centre 0rid buoy

Studlinkanchor chain

^ateral grid buoy.

Grid width 140m

# S8fe:

Grid length 420m Lateralanchor

o 433

Cage ring.

Mooring rope.

V

Mooring bridle

fim

Lateral mooring

Grid rope.

End (axial) anchor

NW

L>

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End (axial) mooring.

S W

Surveyed 1845

« Revised 1897-1904a Levelled 1930

46774 V,__________ ____________i .........m 83600 83700 83800 83900 84000 84100 84200 84300COOl

Scale:- 1:10,560 Scala:- 1:10,560

49372

ITM CENTRE PT COORDS.

j- 485238,548140

DESCRIPTION

MAP SHEETS

6 inchCK116 CK117

OrdnanceSurveyIreland

f Ama thiomsu agus arna fhoilsiii ag Suirbheireacht Ordanais Eireann, Pairc an Fhionnuisce. Baile Atha Ciiath 8, Eire. Compiled and published by Ordnance Survey

| Ireland, Phoenix Park, Dublin 8, Ireland.

I Saraionn atairgeadh neamhudaraithe coipcheart Shui rbheireacht Ordanais Eireann agus Rialtas na hEireann.Unauthorised reproduction infringes Ordnance Survey Ireland and Government of Ireland copyright.

Gach cead ar cosnamh. Ni ceadmhach aon chuid den fhoilseachdn seo a choipeail, a atairgeadh no a tharchur in aon fhoirm na ar aon bhealach gan cead i scribhinn roimh re 6 uineiri anchdipchirlAll rights reserved. No fart of this publication may be copied, reproduced or transmitted in any form or by any means without the prior written permission of the copyright owners.

Nihionann bothar, bealach no cosan a bheith ar an learscail seo agus fianaise ar chead sit. The representation on this map of a road, back or footpath is not evidence of the existence of a right of way.

Ni thaispeanann learscail de chuid Ordanais Shuirbheireacht na hEireann teorann phointi dleathuil de mhaoin riamh, na uineireacht de ghneithe fhisiciula.Ordnance Survey maps never show legal property boundaries, nor do they show ownership of physical features.

*8

© Suirbheireacht Ordanais fireann, 2011 © Ordnance Survey Ireland, 2011

N

3"1 February 2014

Marine Harvest Ireland Application for a Salmon Farm Development in

Bantry Bay (Shot Head) - Additional Information

ContextThe European Communities (Control of Dangerous Substances in Aquaculture) Regulations

2008 (SI 466 of 2008) was introduced for the purpose of giving effect to the Dangerous

Substances Directive (2006/1 I/EC), Habitats Directive (92/43/EEC) and Water Framework

Directive (2000/60/EC), so far as these Directives relate to the discharge of dangerous

substances to the marine environment from aquaculture activities.

SI 466 of 2008 states, inter alia:

Regulation 3( I ):A licensing authority shall not grant an aquaculture licence if, in the opinion of the authority-

fa) the applicant is unable to comply with limits on the quantity and concentration of a

dangerous substance that may be discharged,(b) the applicant is unable to comply with required emission standards,(c) it is necessary in order to secure compliance with environmental quality objectives or

standards,

(d) it is necessary for the protection of human health, plant health, animal health or

welfare, or the environment, or

(e) it is necessary, ancillary or supplementary for an act of the institutions o f the

European Communities (including an act cited in the preamble to these Regulations)

to have full effect.

Regulation 44(1) requires an application for an aquaculture licence to:

(a) identify any dangerous substance which is intended to be discharged,

(b) indicate the quantity of the discharge of each dangerous substance,

(c) indicate the frequency of the discharge of each dangerous substance, and

(d) demonstrate that the intended discharge will not have a deleterious effect on the

environmental quality objectives for the receiving waters.

4(2) It is sufficient compliance with paragraph ( I ) to—(a) address the matters raised in that paragraph in an Environmental Impact

Statement submitted as part of an application, and

(b) demonstrate that the use of a dangerous substance is subject to an equivalent level

of statutory control as provided for in these Regulations.

Regulation 7A licensing authority may require an applicant or licensee to submit plans or other

particulars in relation to the activity to which the application or aquaculture licence

relates, or to the emission or discharge of a dangerous substance due to that activity as

the licensing authority considers necessary for the purpose of determining an

application......

3'1 February 2014

Additional Information RequiredThe information provided in the EIS is sufficient to understand the type and nature of the

dangerous substances intended for use as sea lice treatments and their intended method of

application. There is, however, insufficient information/data on the likely quantity and

frequency of discharge of these substances. Furthermore, the EIS has not adequately

demonstrated compliance with the EQS for these substances , as is required.

In order to ensure that the applicant is in compliance with the requirements of SI 466 2008, and in order to allow the Minister to make a determination on the application, the Marine

Institute recommends that DAFM request the applicant to provide:

I. Information on the:a) Estimated quantity of the discharge of each dangerous substance intended for use at

the site, and

b) Likely frequency of the discharge of each dangerous substance intended for use at

the site.

II. Data and information that would demonstrate compliance with the Environmental Quality Standards (EQS) which apply to each dangerous substance intended for use at the site. This may be based on the output of appropriate models or other relevant

methodology.

This additional information should be also sufficient to allow a more complete assessment of

the impact of dangerous substances on benthic fauna, commercial fish and shellfish.

Note -The information required at la) and lb) above could be based, at least in part, on the

applicant's experience of the use and discharge of dangerous substance at other similar licensed

sites— or other sources, as relevant

1 Available athttpi/Avww.agriculture.gov.ie/media/iniaration/llsheries/aquacullureforeshoremanagement/implementationforaq uacultureofdangeroussubsiancesdirectivc/2DSDEOSDecQ8%2()23()210.pdf

W a t e r m a r kaqua-environmental ballywaltrim house ballywaltrim bray co wicklow ireland

Application by Marine Harvest Ireland for a Salmon Farm Development at

Shot Head, Bantry Bay, County Cork.

Reference T5/555

Additional Information

February 2014.

ClientMarine Harvest Ireland Rinmore Letterkenny County Donegal

telephone +353 (0) 1 2862000 mobile +353 (0) 872481581 e-mail neilbass@iol.ie

Application by Marine Harvest Ireland for a Salmon Farm Development at

Shot Head, Bantry Bay, County Cork.

Reference T5/555

Additional Information

February 2014.

Executive Summary.

This report only considers the likely impact of worst case sea lice treatments at the EQS point, using EmBZ and Deltamethrin. This situation would arise if the entire proposed Maximum Allowable Biomass (MAB) of fish on the proposed Shot Head site, of 2,800 tonnes of stock, required treatment for sea lice.

This report calculates that, if such a Slice® treatment were required, 92.5 tonnes of medicated feed, containing 925mg of EmBZ, would be fed to the stock over the 7-day treatment period. This would result in the release of EmBZ to the marine environment at Shot Head via three different pathways. The report estimates that a total of 27.5mg of the total EmBZ load would be released immediately in waste feed, 89.7mg would be released almost immediately in faeces and the balance of 807.5mg would be retained as body load in the fish (giving them lice protection for ten or more weeks), to be steadily released on an exponential excretion curve, such that 50% of the load will have been excreted after 36 days. The equations are developed for these releases on a daily basis following each day's feeding of the stock. Each day's EmBZ releases are then dispersed using a tidal prism box model, to give an average concentration for EmBZ at the EQS point, that is 24 hours after the completion of the 7-day treatment, in an area of 620m x 340m, or 210,800m2, the perimeter of which lies 100m beyond the treatment area.

It is thus calculated that the mean EmBZ concentration under mean tidal conditions will be 0.196ng/l, against a required EQS of 0.220ng/l.

Treatment with Alphamax® (active ingredient Deltamethrin) at Shot Head would be carried out in the well tanks of the well boat MV Grip Transporter, which has two 600m3 wells. The two wells together are sufficient to hold 100 tonnes of fish for treatment, requiring 120ml of Alphamax® per tank, containing 1.2mg of Deltamethrin. The treatment lasts for 40-45 minutes, within a cycle time for the filling and emptying of the wells with water and fish, which lasts 4 hours per treatment. Treatments are carried out on a 24-hour day basis until complete. Thus, to treat the entire proposed MAB of the Shot Head site, of 2,800 tonnes of fish, would require 28 separate 4-hour treatment cycles and take 112 hours. This would use and discharge 2.4mg of Deltamethrin in the two wells combined, every four hours, or 67.2mg Deltamethrin for the 28 treatments required for the total MAB, over 112 hours.

Since the flushing of the wells takes no more than one hour, within a treatment cycle of 4 hours, the dispersal of Deltamethrin is considered under both mean neap and mean spring tide conditions, using two separate tidal prism models. The flushing from each four-hourly treatment cycle is dispersed separately over the 112-hour treatment period and the dispersal model is continued until the EQS point, 24 hours after the completion of treatment, is reached.

The model projects that the mean dilution of Deltamethrin concentration through the 620m x 340m box, at the EQS point, would be 0.04537ng/l under mean neap tide

conditions and 0.02118ng/l under mean spring tide conditions, compared with the EQS set for Deltamethrin of 2.00ng/l.

The report observes that, although the mean concentrations for both EmBZ and Deltamethrin at the EQS point are found to be below the set EQS's for these two substances, the calculations are worst case and highly conservative. In consequence, the actual values, 24 hours post treatment 100m from the treatment site, are likely to be much lower than predicted, for a variety of reasons. Amongst these are the fact that, rather than a mean value applying across the selected box area, a concentration gradient will apply. Other studies are cited that suggest that the concentration at the EQS point will be at least 90% less than the concentration close to the centre of the treatment area. In addition, only still weather conditions are considered in the calculations.

It should also be noted that it has never proved necessary to treat more than one tenth of the worst case MAB treatment modelled in this exercise in Bantry Bay, that lice treatments are rarely required in Bantry Bay, that no lice treatments have been required on MHI Bantry Bay stocks in the last two years and that, for some generations of stock, no lice treatments are required at all.

Application by Marine Harvest Ireland for a Salmon Farm Development at

Shot Head, Bantry Bay, County Cork.

Reference T5/555.

Additional Information

February 2014.

Main Report.

2.1. Salmon farms in Bantry Bay.Two companies operate marine salmon farm sites in Bantry Bay. MHI operates a grower site and a smolt site at Roancarrig and Ahabeg respectively, between Bear Island and Roancarrig Rocks. Murphy's Irish Seafood (AKA Fastnet Irish Seafood) operates a grower site and a smolt site to the west of Whiddy Island, on the southern shore of the bay. The proposed MHI Shot Head site, which is the subject of the additional information request answered in this document, lies between these two groups of sites; see Figure 1.

2.2. Sea lice monitoring in Bantry BayAs for all Irish salmon farms, a regime of statutory sea lice monitoring has been conducted on a regular basis in Bantry Bay by officers of the Ml since 1991. This program also forms the basis of a statutorily required treatment regime. Under the May 2000 protocol1, farms are inspected a minimum of 14 times per annum, twice monthly during the "sensitive period" of March to May, when wild salmonid smolt are migrating seawards, and otherwise once monthly, except between December and January, when only one inspection takes place. In addition, the lice levels at which lice treatment is triggered by the monitoring program, is reduced to an average of 0.5 ovigerous female lice per fish inspected between March and May, whereas the trigger level is an average of two ovigerous female lice per fish inspected for the rest of the year. The primary objective of this program and the set trigger levels is to minimise the numbers of ovigerous female lice on the farmed stock and, thereby, to reduce ambient levels of infestive copepodid larvae, in order to control re-infestation of farmed stock but especially to reduce infestation pressure on wild salmonids from farmed-origin lice.

In addition to this statutory regime, MHI conducts its own lice surveys up to once per week, depending on season and will also respond with treatments at lower trigger levels than those set by the Ml.

The results of the Ml national sea lice surveys are published annually and can be found on the Ml website. The Ml monitoring record for the salmon louse (Lepeophtheirus salmonis) for the MHI sites in Bantry Bay for the years 2008 to 2013 is shown in Table 1, along with MHI's lice treatment record for the period.

Table 1 shows that, on the basis of the Ml's statutory lice monitoring program, salmon lice levels have remained extremely low at MHI's Bantry Bay sites. In consequence, very few sea lice treatments have been required and responses to treatment have been good. Much the same applies to other sites in the southwest of Ireland, both belonging to MHI and to other operators in the area.

Section 2.Sea lice and sea lice treatment in Bantry Bay.

1 Monitoring Protocol No. 3 for Offshore Finfish Farms - Sea Lice Monitoring and Control. DCMNR, May 2000.

Bant

ry B

ay s

alm

on fa

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ites

(lice

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and

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pose

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ith s

epar

atio

n di

stan

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Monitoring record of infestion by Lepeophtheirus salmonis (salmon louse) on SO salmon stocks on MHI Bantry Bay sites, at Roancarrig and Ahabeg, and lice treatment frequency, 2008-2013.

Treatment key [ 1 Slice | ~| Hydrogen peroxide

Notes 1 Data abstracted from Ml Monitoring Reports. 2008 to 2012.3.2. 2013 data provisionsal and end month only; Ml 2013 Monitoring Report has not yet been published.3. Note that there has never been an Alphamax treatment on a MHI site in Bantry Bay.4. Total number of treatments since 2008; 3 x Slice’ and 3 x Hydrogen peroxide.5. There have been no treatments at all on MHI sites in Bantry Bay since April 2011.

Table 1.

Stock DateT reatment

trigger level

Ovigerousfemale

lice

Juvenile + mobile

lice

Totallice

SO 16th Jan 2008 2 . X2007 Feb 2008 2 . X

SO 2007 harvest completedSite fallowed before restock ng

16th Jan 2008 ' 0 0 O X 0.31 0 316th Feb 2008 z o o 0.02 0.25 0.274th Mar 2008 0.50 O X 0.04 0 0 419th Mar 2008 0.50 0 . X O .X 0.002nd Apr 2008 0.50 O .X O .X 0 0015th Apr 2008 0.50 O .X 0 02 0 028th May 2008 0.50 0 . X 0.02 0 02

22nd May 2008 0,50 0 . X 0.00 0 0013th Jun 2008 2 . X O X O .X o x18th Jul 2008 2 . X 0.03 0.13 0.15

o 20th Aug 2008 2.00 0.09 0.55 0 64

8th Sep 2008 2 . X 0.08 0.34 0 4 2s 14th Oct 2008 2 . X 0 2 5 0.36 0 61

5th Nov 2008 2 . X 0.17 0.23 0 4011th Dec 2008 2.00 0.00 O .X 0 0 03rd Feb 2009 2 . X O .X 0.02 0.0212th Mar 2009 0.50 O .X O .X 0.0026th Mar 2009 0.50 O .X 0.04 0 048th Apr 2009 0.50 o x 0.02 0 02

23rd Apr 2009 0.50 O .X 0.22 0 2212th May 2009 0.50 O .X 0.11 0.1120th May 2009 0.50 0.02 O .X 0 1111th Jun 2009 2 . X O .X 0.07 0.13

SO 2008 harvest completedSite fallowed before restocking

11th Dec 2008 2.00 o 8 O .X 0 093rd Feb 2 X 9 2 . X O .X 0.02

r i o

o

12th M ar 2 X 9 2 . X O .X O X 0 0 026th M ar 2 X 9 2 . X O .X 0.04 0 048th Apr 2009 2 . X O .X 0.02 0 0 2

23rd Apr 2009 2 . X o x 0.22 0 2 212th M ay 2009 2,00 O .X 0.11 0.1120th M ay 2 X 9 0.50 0.02 O .X 0.1111th Jun 2009 0.50 0 06 0.07 0 1323rd Jul 2 X 9 3,50 0 06 0.12 0 1813th Aug 2 X 9 0.50 O X O .X O X

§ 1C*h Sep 2 X 9 0 50 0 1 2 O .X 0 18CM 5th Oct 2009 0.50 0.02 0.04 o o ss IQtfc Nov 2009 2 . X 0.04 0.31 0 35

10th Dec 2 X 9 2 . X 0 02 0.24 0 252nd Feb 2010 2.00 0.13 0.36 0 49

2nd M ar 2010 0.50 0.14 0.48 0 6223rd M ar 2010 0.50 0 33 1 19 1 528th Apr 2010 0.50 0.39 1.30 1 69

22nd Apr 2010 0.50 O .X O .X 0 004th May 2010 0 50 0 03 0.52 0 55

26th May 2010 0.50 0.15 0.79 0 9415tr Ju r 2010 2 . X 0 04 0.14 0 18fihJilS 2010 2 X 0 / 0 0.25 0 35

27i« . a y 2010 2 X 0 / 0 0.20 0 303 0 2009 h on est comp etea

S te fai'-owed before restock ,r ,a ____ ___ ___________ i

Stock DateT reatment

trigger level

Ovigerousfemale

lice

Juvenile + mobile

lice

Totallice

1

%

24th Nov 2010 2 . X 0 00 0 00 e x14th Dec 2010 2 . X O .X O .X O .X9th Feb 2011 2 . X 0 00 0 00 COD2nd M ar 2011 2 . X O X o x 0.00

23rd M ar 2011 2 . X O .X 0.03 o x8th Apr 2011 O .X O .X O X 0.00

20th Apr 2011 O .X O X O.X 0.004th May 2011 O .X O .X GOO e x19th May 2011 O .X 0 00 COO 0.0015th Jun 2011 2 . X 0 00 002 0.025th Jul 2011 2 . X 0.00 002 0.02

11th Aug 2011 2 . X 002 0 05 0 .0320th Sep 2011 2 . X o x 0 02 O .X12th Oct 2011 2 . X 0 00 0 03 O .X9th Nov 2011 2 . X 0 00 0 00 O .X10th Jan 2012 2.00 O .X 0 0 4 0 0 421st Feb 2012 200 o x ooo O .X6th Mar 2012 0 50 0.00 0 02 0.02

23rd M ar 2012 0 5 0 O .X 0 0 4 0.0412th Apr 2012 0 50 0.00 ooo O .X25th Apr 2012 0 50 0.02 0.04 O .X16th May 2012 0 50 0.02 0.14 0.1625th May 2012 0 50 0.02 0 0 4 O X20th Jun 2012 2.00 0.00 0 02 0.02

4th Jul 1012 z o a 0 0 0 OOO O XSO 2011 harv

Site fallowed b€Bst completed *ore restocking

CM1

8

10th Jan 2012 2.00 0 00 O X O .X2 1 st "eb 2012 200 0 00 O X O .X6th M ar 2012 0 50 ODD 002 0.02

23rd Mar 2012 0 50 0 00 0 01 0 0 112th Apr 2012 0 50 0 00 OOO O .X25th Apr 2012 0 50 0 00 0.00 0.0016th May 2012 0 50 0 00 GOO 0.0025th May 2012 0 50 0 00 0 00 o x20th Jun 2012 2 00 o x 0 00 O .X4th Jul 2012 2.00 0 00 Q X co o7th Aug 2012 2.00 O .X 0 05 0 0 518th Sep 2012 2 0 0 0.07 0 OS C.1319th Oct 2012 2 00 O .X ooo O .X8th Nov a » 2 O .X 0 03 C.03end Jan 2013 2 . X 0 00 OOO O .Xe ra Feo 2013 2 . X 0 30 o o o e xend M ar 2013 O .X 0.00 0 00 0.00enc Apr 2013 O .X 0 00 0 10 0.10end May 2013 O .X 0 00 g e o 0.00end Jun 2013 2 . X 0 00 ooo 0.00

SO 2012 harvest completed S *e fallowed before restocking

toi

s

end Jan 2013 2.00 0 00 0 03 0 0 3e ra Feo 2 01 3 2 . X 0 00 o 02e ra M ar 2 0 13 0.50 0 00 C 03 C.03end Apr 2013 O .X 0 00 0 09 0 COe^a May 2013 O .X 0 00 0 00 0.00end Jun 2013 2 . X 0 00 1 CCO 0.00e ra j ul 2013 O .X 0 00 ODD oco

e re Aug 2013 0 5 0 0 00 0 CO O .Xenc Sep DO! 3 0 50 0 99 0 GO O Xe re Oct 2 0 '3 0 50 0 00 1 0 00 cooe ra Nov 2013 0 . X 0 00 1 C CO c coe^o Dec 2C13 0.50 j r- 43 0 CO

3.1. Lice treatment history on MHI's Bantry Bay sites.Table 1 shows that lice treatments have rarely been required on MHI's Bantry Bay sites, with only three Slice® treatments conducted since 2008, on recently transferred, SO fish. 130 tonnes of fish were treated with 23kg of Slice® in February 2008, 260 tonnes were treated with 45kg of Slice® in December 2008 and 160 tonnes of fish were treated with 27,5kg of Slice® in December 2010. The only other sea lice treatments carried out were a series of three, using a total of 52,2001 of Hydrogen Peroxide, on older fish. There has never been an Alphamax® treatment on MHI's Bantry Bay sites.

3.2. Lice treatment methodologies and calculation of treatment dose.Only three anti-lice medications are used by MHI. The company reviews treatment choice as required, subject to the assessment of new treatments and techniques and the monitoring of treatment regime efficacy. As with many of their operational procedures, MHI controls lice treatment via Standard Operating Procedures (SOP's). In-house lice monitoring procedures are also controlled by a specific SOP, as are lice treatment rotation and identification of sub-optimal lice treatments. The 2011 Shot Head EIS reviewed the SOP's for lice treatment. However there have been some changes in treatment strategies since that time.

The three lice treatments currently used by MHI are Slice® via in-feed application, Alphamax® by in-well boat bath and Hydrogen Peroxide, either by in­well boat bath or by in-pen bath, using a fully enclosed tarpaulin bag. The SOP's for these three methodologies and lice monitoring and treatment rotation are attached in Appendix 4. The SOP for Alphamax® has recently been updated.

Since Hydrogen Peroxide is not subject to an EQS (see Appendix 3) and its breakdown products are innocuous (water and oxygen), this treatment is not considered further in this document.

Slice® dosage is calculated from the fish biomass to be treated. Table 2 shows the growth model from the EIS for the proposed Shot Head operation. This is used to calculate the worst case treatment dose, at the Maximum Allowable Biomass (MAB) for the site. New aquaculture licence templates issued by DAFM indicate that, if Shot Head is granted a licence, it is likely to be based on MAB. MHI seeks a licensed MAB of 2,800 tonnes for the Shot Head site. Should the need arise to treat the entire MAB, this will require the worst case treatment dose. It should be noted from Section 3.1 that the worst case Slice® dose, of 490kg for 2,800T of fish, would be eleven times greater than the largest Slice® dose ever used historically on MHI's Bantry Bay sites, of 45kg, in December 2008.

Section 3.Characterising and quantifying a lice treatment regime for Shot Head.

Projected multi-generation grow-out model for proposed Shot Head site, showing Maxiumum Allowable Biomass (MAB) sought, in February to March in alternate years.Note S D = Stocking density

Table 2.

Year i MonthMonthsgrowth

Fish number Mortality Meat weight gms Total Biomass T Biogan Harvest

FCRFeed

used T / monthStart month End month

% per month

Number / month

Startmonth

End | month

Startmonth

Endmonth

monthtonnes Number

Mean w* *9

Harvesttomes

835 884 ; 814 937 250 20 897 75 ! 101 62 7 823 196 0 0 0 095 186814 987 802 752 150 12 225 101 | 141 82 3 1132 309 0 0 0 095 293802 762 796 340 080 6422 141 198 1132 157 7 445 0 0 0 103 445796 340 ! 792 358 050 3 962 198 J 275 157 7 217.9 602 0 0 0 1 1 0 €62792 358 i 788 397 0 50 3962 275 I 375 2179 295 6 77 8 0 0 0 1 2 0 633788.397 J 784 455 0 50 3942 375 ! 505 295 6 396 1 1005 0 0 Q 1 2 0 1206784.455 I 777 394 0 90 7060 505 ! 670 396 1 520 9 1247 0 0 0 123 1528777 394 I 768 066 1 2 0 9 329 670 : 880 520 9 6759 1550 0 o 0 125 193 8768 066 j 756 545 150 1 "521 880 | 1130 675 9 854 9 1790 0 0 0 127 2273756.545 ! 739144 2.30 17.401 1 130 1.417 854 9 1.G47 4 192 5 0 0 0 127 244 473S 144 ' 725840 180 13 305 1417 ; 1745 1,047 4 1266 6 2192 0 c 0 127 278 4725.840 i 721485 OK) 4 355 1745 j 2 1 2 0 1 266 6 1 529 5 263 0 0 0 0 127 334 0721.485 I 712 827 1 2 0 8 658 2 1 2 0 j 2.550 1.529 5 1.817 7 288 2 0 0 0 127 3660712.827 1 707 124 080 5 703 2 550 | 3.025 1 817 7 2 139 1 321 3 0 0 0 127 408 1707 124 I 702.174 0.70 4 850 •3 025 I 3.540 2.1391 2.485 7 3466 0 0 0 127 4402702 174 I 693 748 1.20 3426 3 540 j 4 036 2485 7 2.800 314 3 0 0 0 127 3991693 748 I 600423 1 20 ‘3 325 4 036 4 534 2,800 2 722 3 3049 85 000 4 500 382 50 127 3872600 423 | 475620 0 80 4 803 4.534 j 4 975 2 722 3 2.366 2 207 9 12 0 0 0 0 4 700 564 00 127 2640475 620 I 336815 0.80 3 805 4.975 ! 5.248 2.366 2 1.767 6 11 01 135000 5250 708 75 127 1399336 815 I 229.794 0.60 2 021 5 248 | 5420 1.767 6 1 245.5 449 105 COO 5400 567 00 127 57 0229 794 l 118 645 050 1 149 5420 I 5 544 1 245 5 657 3 283 110 COO : 5600 61600 127 359118 645 0 040 475 5 544 ( 5 600 657 8 0 0 40 118170 5 600 661 75 127 51

Harvest completed. Site fallow until next smolt input.835 884 ! 814 987 250 20.897 75 101 62 7 823 196 0 0 0 095 186814 987 1 802 762 150 12 225 101 141 82 3 1132 309 0 0 0 0.95 293802 762 j 7% 340 0.80 6422 141 198 1132 157 7 445 0 0 b 1 0 0 445796 340 | 792 358 050 3 982 198 l 275 157 7 2179 602 I 0 0 b 1 1 0 662792.358 I 788 397 0 .5 0 3 962 275 | 375 2179 295 6 77 8 0 0 0 1 2 0 633788 397 j 784.455 0.50 3942 375 ! 505 2956 3961 100.5 0 Q o 1 2 0 1206784.455 I 777 394 0 90 7060 505 j 670 396 1 520 9 124 7 0 o 0 123 1528777.394 1 768 066 1 2 0 9 329 670 880 520 9 675 9 1550 0 0 0 125 193 B768 066 i 756545 150 11 521 880 ]" i 130 675 9 854 9 1790 0 0 0 127 227 3756 545 I 739.144 2.30 17401 1 130 j 1417 854 9 1.047 4 1925 0 0 0 127 244 4739 144 j 725840 180 13.305 1.417 i 1J45 1.047 4 1.266 6 2192 0 0 0 127 278 4725 840 l 721 485 060 4 355 1 745 i 2 .120 1 266 6 1,529 5 2630 0 0 0 127 334 0721.485 [ 712827 1 20 3658 2.120 2.550 1.529.5 1,817.7 2882 0 0 0 127 366 0712 827 707.124 0 80 5703 2.550 t 3.025 1.817.7 2.1391 3213 o o 0 127 4081707 124 702174 070 4 950 3.025 t 3.540 2.1391 2.485.7 346 6 6 0 0 127 440 2702,174 I 693 748 1 20 3426 3,540 I 4036 2.485.7 2.800 314 3 0 0 0 127 3991

693 748 ■ 600 423 1 20 8 325 4 036 i 4.534 2,800 2722 3 3049 85.000 4 500 382 50 127 387.2600 423 j 475620 080 4803 4 534 ! 4.975 2 722 3 2 366 2 207 9 1 2 0 0 0 0 : 4 700 564 00 127 264 0475 620 | 336815 080 3805 4 975 I 5 248 2 366 2 1 767 6 1101 135 COO j 5 250 708 75 127 1399336 815 229.794 060 2 0 2 1 5.243 j 5,420 1.767 6 1,2455 449 105 COO j 5400 567 00 127 ; 570229 794 118 645 050 1 149 5420 i 5,544 1.245 5 6578 283 110 000 | 5600 61600 127 359118 645 0 040 475 5 5 4 4 1 5,600 657 8 0 0 40 118170 5600 661 75 127 51

Harvest completed. Site fallow until next smolt input.83-5.884 814 987 250 20.897 75 101 82.7 823 196 o i 0 0 0.95 186814987 ! 302 762 1 50 12 225 101 I 141 823 H32 309 0 o 0 0.95 293802762 1 796 340 0.80 6422 141 j 198 1132 1577 445 0 G 0 ib o 445796 340 ! 792 358 050 3 982 196 ! 275 157 7 2179 602 0 0 0 1 10 662792.358 1 788 397 050 3 962 275 T 375 217 9 295 6 77 8 0 0 0 1.20 S3 3788 397 t 784 455 053 3942 375 j 505 295 6 396 1 1005 0 0 0 1 2 0 1206784.455 ! 777 394 030 7060 505 ! 670 3961 520 9 1247 0 0 0 1.23 152 8777 394 | 768.066 1 20 9 329 670 880 5209 675 9 1550 0 b 0 125 193 8

768,066 i 756 545 1.50 11 521 880 ! 1130 6759 854 9 1790 0 0 0 127 2273

756 545 j 739.144 2 30 17401 1 130 i 1.417 854 9 1.047 4 1925 0 0 0 127 244 4

739 144 j 725840 1 SO 13 305 1417 [ 1.745 1.047.4 1 266$ 2192 0 0 0 127 2784

725 840 ! 721485 0 60 4 355 1.745 I 2.120 1.266 6 1,529 5 2630 Q 1 n 0 127 334 0

721 485 | 712827 1 2 0 3658 2 1 2 0 S 2 550 1 529 5 16177 2882 0 0 o 127 366 0712 827 707 124 0 83 5 703 2 550 ! 3.025 1.8177 2.139 1 321 3 0 0 0 127 4081707 124 i 702174 0 70 4 950 3 025 1 3 540 21391 2465 7 3466 0 o 127 4402702 174 I 693 748 1.20 3426 3 .5 4 0 1 4 036 2 485 7 2.800 314 3 o o 0 127 3991693 748 600423 1 20 3 325 4 036 ; 4 534 2,800 2722 3 3049 85 DOC 4 500 382 50 127 3372

600423 I 475620 080 4 803 4 534 ! 4.975 2722 3 23662 207 9 120 COO 4 700 564 00 12 7 264 0

475 620 336815 0 80 3 805 4 975 1 5 248 2 366 2 1 767 6 110 t 135 COO 5250 70S 75 127 1399

336 315 ; 229794 060 2 C21 5 2 4 3 i 5 420 1767 6 1.2455 449 105000 5 4 0 0 567 00 127 570?9<i 794 1 118645 050 1 149 5420 j 5 544 1 245 5 657 3 283 110 COO 5 6 0 0 616 00 127 3 5 9

118 645 o 040 475 5 544 1 5 600 657 8 0 0 40 119170 5600 664 75 127 51

Harvest completed. Site fallow until next smolt input.

NovDec"JanFebMar

AprMayJunJui

_AugSepOctNovDecJanFebMarAprMayjunJutAug

_l_T ’345_6f8910

12131415161718 19m21n"

SepOct"

2324

NovDecJanFebMarApr_MayJunJiiAugSepOctNovDecJan

J=ebMar"AprMayJun

Jul

JteLSepOctNovDecJanFebMarAprMayJunJulAugSepOctNovDecJanFebMar

.. jfef.MayJunJul

I*5LSepOct

13456

”T"8910 11 121314 15' 1617 ~181920 21 222324

23456

10it!2131415

1617181920 21 222324

3.2.1. Slice® in-feed treatment dosage.Slice® is a proprietary pre-mix 0.2% of Emamectin Benzoate (EmBZ) on an inert matrix, for surface coating of salmon feed, at 5kg Slice® / tonne of feed. Slice® is supplied in 2.5kg sachets, thus containing 5g of EmBZ. Thus one sachet is sufficient to produce 500kg of medicated feed. The recommended dose rate is 50pg EmBZ per kg of fish biomass per day for seven consecutive days. Thus each tonne of biomass requires 5kg of medicated feed per day (giving a feed rate of 0.5% body weight per day) for the seven-day treatment period. Slice® medicated feed is supplied via a feed manufacturer or specialist coating mill, which top coats the Slice® pre-mix, supplied to them under veterinary prescription, onto the ration

Slice® is effective against all lice stages. It acts by binding to specific high-affinity binding sites on lice, resulting in increased membrane permeability to chloride ions and disruption of a number of physiological processes, most notably neurotransmission. Slice® protects fish from lice for ten or more weeks, subject to temperature. Table 3 shows the calculations for EmBZ dosage from projected monthly fish biomass. The table also shows EmBZ excretion pathways; see Section 4.

Table 3.Shot Head Slice® model; dosage and excretion; expressed as mg EmBZ.Notes

1. Shows EmBZ dose required at mean monthly biomass and resulting waste streams.2. Peak dosage occurs at peak site biomass (MAB).3. There are three EMBZ waste streams; see Section 4.

C o lum ns Fo r u se for derivation of d ispersion m odel inputs; s e e Section 4

Peak d o se / d ischarge periodMaxim um Allowable B io m a ss sought (M AB).

Total Biomass T EmBZ dose, fed @ Em BZ partition p e r day Em BZ partition per 7- 'reatn'en:Month begm end 50ug/kg fish b * day W asted in W asted in | Body load W asted m I W asted In Body load

month month mg ‘ day 7 days mg feed mg faeces mg ! retained mg feed mg faeces mo retained mg

1 Nov 62.7 82 3 3 .625 2 5 3 7 6 0 .109 0.352 3 .1 6 5 0.761 2 4 6 1 2 2 1 5 3

2 Dec 82.3 1 1 3 2 4.888 34 2 1 3 0 .147 0.474 4 .267 1.026 3 .319 2 9 8 6 8

3 Jan 113.2 157.7 6 .772 47.401 0 .203 0 .657 5 .912 1.422 4.598 41.3814 Feb 157 7 2 1 7 9 9 .389 6 5 725 0 .282 0.911 8 .197 1.972 6 3 7 5 57 .3785 M ar 2 1 7 .9 2 95 .6 12.839 8 9 8 7 1 0 .385 1.245 I 11 .208 2 .696 8 .717 78 .457

6 Apr 2 95 .5 396.1 17 2 9 5 121 065 0 .519 1.678 I 15 .098 3 6 3 2 j 11.743 105 .6897 Mav 396.1 520 .9 22 .925 160 .476 0 .688 2 .224 I 20 .014 4 .814 | 15.566 140 .095

8 Jun 520 9 6 7 5 9 29 .919 2 0 9 4 3 2 0.898 2 .902 j 26 .119 6 2 8 3 ! 20 .315 182.834

9 Jul 6 75 .9 854 .9 38.270 2 6 7 .8 8 9 1.148 3.712 | 33 .4 1 0 8 .037 I 25 .985 233 .867

10 Aug 8 5 4 9 1.047.4 47 .557 3 3 2 896 1.427 4 .613 I 41 .517 9 .987 ! 32.291 2S 0.613

11 1.047.4 1.266 6 57 .849 4C 4.943_, 1.735 5.611 I 50 .502 12.148 39 .279 353 .515

12 O ct 1.266 6 1 .5 2 9 5 69 .903 4 8 9 324 2 .097 6.781 j 6 1 .0 2 6 14.680 ! 47 .464 4 2 7 .180

13 Nov 1.529.5 1.817 7 83.681 5 8 5 .770 2 .510 8 .117 ! 73 .054 17.573 ! 56.820 511 .377

14 D ec 1.817.7 2 .139.1 98 .919 6 9 2 .433 2.968 9 .595 ! 86 3 5 6 20 .7 7 3 ; 67 .1 6 6 604 .494

15 Jan 2 .139 1 2 .485 7 115.619 8C9.331 3 .469 11.215 1 100 .935 24 .280 7 8 505 7 0 6 .546

16 Feb 2 .485 7 2 .800 1 3 2 .142 i 9 2 4 .991 .3 .9 6 4 1 2 * 1 8 I 115 .360 2 7 .7 5 0 I 89 .724 .: J S m 5 1 7 . ,17 M ar 2.800 2 .722 .3 138 .057 966 .400 4 .142 13.392 ! 120.524 28 .992 93.741 843 .667

18 Aor 2 .7 22 .3 2 .366 .2 127 .213 890 .492 3 .816 12.340 j 111 .057 26 .715 86 .378 777 .400

19 Mav 2.366.2 1.767 6 103 .345 7 2 3 .417 3 .100 10.024 ! 90 220 21 .7 0 3 | 70.171 6 3 1 .543

20 Jun 1.767.6 1,245 5 75 .327 527 .290 2 .260 7 .307 ! 65.761 15.819 i 51 .147 4 6 0 .324

21 J J 1.245.5 6 5 7 8 47.581 3 3 3 069 1.427 4 6 1 5 ! 4 1 5 3 8 9 9 9 2 I 3 2 308 2 9 0 .769

22 Au3_ 6 5 7 8 CO 15.444 115 .110 0 .493 1.595 j 14.356 3 .453 11.166 100.491

23 ___ Sep- S h o t H e a d s i t e f a l l o w

3.2.2. Alphamax® treatment dosage.The active ingredient in Alphamax® is the synthetic pyrethroid Deltamethrin, which is effective against pre-adult and adult lice stages. Pyrethroids are a group of natural and synthetic chemicals which act on insects and related organisms (such as sea lice) by blocking neural transmission pathways. Deltamethrin does not bioaccumulate in fish and, if released into the environment (for example if in-cage treatment is employed), less than 10% persists (and this part is widely dispersed) after 10 days, whilst its half life in sediments under treated cages has been found to be 140 days, with 90% biodegraded by 12 months. However these are not now issues for MHI who use enclosed welt boat tanks for Alphamax® treatments.

Treatment dosage and duration is 0.2ml Alphamax® (= 2pg Deltamethrin) per m3 seawater in the well tank for 40-45 minutes. See SOP 29142 Version 4 in Appendix 4 for procedural information.

The well boat MV Grip Transporter that would be used for Alphamax® treatments on the Shot Head site has two 600m3 tanks. These would require a total dose of 120ml of Alphamax®, containing 1,200pg (1.2mg) of Deltamethrin, per tank, per treatment. The well boat tanks have the combined capacity to treat 100 tonnes of fish per treatment. Thus the total tonnage of fish for treatment is also material to the total dosage of Alphamax® to be used.

Alphamax® treatment by well boat is conducted on a 24-hour-day basis, with each treatment period lasting a maximum of four hours, from the crowding and pumping of the fish from the fish pens into the well tanks, to their release, post treatment, back to the pens. Thus, in the worst case scenario, to treat the total MAB (see Table 2 and 3) of 2,800 tonnes of stock, a total of 28 four-hourly treatment periods would be required, lasting a total of 112 hours (4.67 days). This procedure would require the use of 240ml of Alphamax® (containing 2,400pg of Deltamethrin) per 4- hour treatment cycle, or a total of 6,720ml of Alphamax® (or 67,200pg of Deltamethrin) for the full treatment of 2,800 tonnes of fish over 4.67 days.

Section 4.Waste loadings, dispersal and fate of EmBZ and Deltamethrin treatments.

4.1. Loadings, dispersal and fate of EmBZ.See Table 3. It has been determined that the EmBZ 0.2% active component of Slice® passes to waste from the in-feed treatment process via a number of pathways 2. Of the feed fed to each pen, 3% is regarded a non-ingested waste. Of the balance of 97% of the feed that is ingested, 10% is voided from the fish almost immediately in the faeces. Of the remaining 90% of EmBZ, known as the "body load", approximately 99% is excreted over the subsequent 216 days. This excretion has an exponential decay profile described by the equation

Mt = M o x e ^

Where M0 = mass of EmBZ in the fish prior to its excretion MT = Mass of EmBZ excreted at time T T = timex = excretion rate factor, determined to be -0.019254088 e = exponential function

The determination of x, the excretion rate factor, is based on the half-life of the excretion process, that is when 50% of the body load has been excreted. This has been calculated to take 36 days. It has been further determined that EmBZ breaks down into “non-toxic” sub-compounds with a half-life period of 250 days 2.

Table 3 partitions the fate of EmBZ into these three streams, as EmBZ in waste feed (3%), EmBZ in faeces (immediate; 10% from the remaining 97% of feed) and remaining EmBZ body load (90% of 97%), on a per day and a per 7-day, full treatment span basis. These figures are derived arithmetically from mean monthly biomass data, abstracted from the growth model in Table 2. Thus for either each day of the 7-day treatment period, or for the entire treatment period:-

EmBZ dose = EmBZ wasted in feed waste + EmBZ wasted in faeces + body load.

Figure 2 shows the exponential decay curve for the EmBZ body load, derived using the exponential decay equation. The inset curve details the EmBZ body load decay over the 7-day treatment period and just beyond it, to 10 days.

Using these data, the percentage of daily body load excreted can be calculated over any period. Table 4 calculates this for the initial ten days, from commencement of the 7-day treatment period.

2 SEPA, 2005. Regulation and monitoring of marine cage fish farming in Scotland. Annex H; Methods for modelling in-feed antiparasitics and benttc effects.

Perc

ent b

ody

load r

emain

ing

Figure 2. Exponential curve for % EmBZ body load remaining.

Time days

Table 4.Percent body load loss, for days 1 to 10.

Key 7-day treatment period. 24 hours post treatment.

Day Body load remaining %

Body load loss %Cumulative Daily

0 100.00 0.000 0.0001 98.093 1.907 1.9072 96.222 3.778 1.8713 94.387 5.613 1.8354 92.587 7.413 1.8005 90.822 9.178 1.7666 89.090 10.910 1.7327 87.391 12.609 1.6998 85.724 14.276 1.6679 84.090 15.910 1.63510 82.486 17.514 1.604

The daily % body load loss data (daily EmBZ % excretion rate) given in Table 4 can then be used to calculate the actual daily loss of EmBZ by weight, from worst case data given in Table 3, which shows the accumulation of a body load of 115.360mg of EmBZ per treatment day for the in-feed treatment of a biomass of 2,800 tonnes of salmon with Slice®, over the required 7-day treatment period.

To calculate the dispersal of EmBZ in feed and faecal waste and in the excreted EmBZ body load, it is first assumed as a worst case that the total load remains in the water column. A tidal prism box model is then employed, as used for box modelling in the Shot Head EIS 3. The box area used is to 100m beyond the treatment area, referred to in the EQS specifications; see Appendix 3.

With reference to the Shot Head EIS, the area within which the treatment takes place and the active ingredient is first discharged, by whatever route, is taken as the grid area for the pens, which measures 420m x 140m for Shot Head. The addition of 100m to all sides of this gives an EQS area, as defined, of 620m x 340m, or 210,800m2. As in the EIS, the low water depth at the site area is taken as 37.1m, mean neap tidal range as 1.3m and mean spring tidal range as 2.9m. A mean tidal prism model is used because at 7 days, the treatment period takes up almost half of the spring / neap cycle time of 15 days and mean tidal current conditions can be expected to apply. The tidal prism model is shown in Table 5.

Table 5.Mean tidal prism model for selected site box area of 620m x 340m (210,800rrf).For calculation of worst case EmBZ water column dispersal with 7-day Slice® treatment.

Parameter Notation Data UnitsNotional box low water sea area A 210.800 m2Notional box mean low water depth D 37.10 mThus notional box mean low water volume V = A x D 7.820.680 n rMean tidal range neap tide Rn 1.30 mMean tidal ranqe spring tide Rs 2.90 mThus mean neap tidal volume Pn = A x Rn 274.040 m3Thus mean spring tidal volume Ps = A x Rs 611.320 n rMean neap flushing time (tidal cycles) Tn = (V + Pn) / Pn 29.54 tidal cyclesMean spring flushinq time (tidal cycles) Ts = (V + Ps) / Ps 13.79 tidal cyclesThus mean neap flushinq time (days) Dn = Tn / 2 14.77 daysThus mean spring flushing time (days) Ds = T s / 3 e ljo lThus mean daily flushing rate litres Fd =(((V / Dn)+(V/Ds))/2) x 1000 831.761.904 litres 1 day

The dispersal of the EmBZ effluent streams, as derived for worst case from Tables 2 to 4, is now calculated to give mean the EmBZ concentration across the selected box area using the mean daily flushing rate of 831,761,904 litres/day derived from Table 5. This is shown, in ng EmBZ / litre mean concentration, in Table 6, where each category of waste is dispersed per treatment day separately and the data aggregated to give daily mean dilution values for the EQS box area.

As well as showing the dilution 24 hours post-treatment (in bold red to the bottom right of Table 6; 0.19563ng/l), daily mean concentrations are given, along with the value 48 hours post-treatment. This shows that the peak value of 0.19563 is transitory, related to the progressive dosing of the system with EmBZ over the 7- day treatment period and the termination of dosing at the end of day 7. 1

1 Edwards A, Sharpies F. 1986. Scottish Sea lochs; a catalogue. SMBA/NCC 110pp

Table 6.Dispersal concentrations of EmBZ in mean tidal conditions, ng/l.

I.22

Slice feeding detailsReleased EmBZ treatment dilution ng l within 1 0 0m of site

day feeding periods)by hour given i?x1

s —48 tours post | treatment rg /l

1Treatment day

Treatment end ihcnKS) _

O-jantrty released ng

0-24 hours 0-» 48 hotfs 0-72 hours 0-95 hours0 -1 2 0

tm e s

0-144hours

0-168boil's 165-24 16S-4S

1 24 3,964 248 000477 0 ->3238 0 00159 000119 0 90096 0 00079 0 0X63 ! o sums1 0 09X3

I 2 48 3 964 248 0 00477 0 00238 000159 0.00119 0 00096 0 (>0079 0 03Q8& I 0059606 3 72 3.964 248 0 00477 000238 0.00169 0 00119 0 03096 3 iXiOTS D00068 I

14 se 3 964 248 0 00477 G 00238 000159 0 00119 i 0 OitDTS i

..£ 5 120 3 964.248 0 00477 0 00238 0 00159 0 031 IS < O0»0f956 144 3 964 248 0 004?7 0 03238 : 03159 G 03119

E 7 1® 3 <*4 248 i 0 X 4 7 7 . OOOlMPost-treatment 24 (»

1 24 12817736 0.01541 0 00771 0 00514 000385 0.00308 000257 0 00220 i 003193 D03171 i2 48 12.817 736 0 01541 0.00771 0 00514 0 00385 0.00308 0 00257 i D 001193

1 3 72 12817736 001541 0'00771 0 00M4 -0.1343381 0 00308 j 00325? 00922042 4 96 12 817 736 001641 0 00771 0 00514 0 08386 r (0308 003257M 6 120 12 317 736 j 0.01541 0 00771 0 00514 0 03356 D 03008

6 144 12 817 736 0 01541 0 00771 2 00614 D 0-3385LU 7 168 12 517 736 i n > « 4 i •3 03771 0 00*614

Post treatment 24 Cl 0090*30

| |1 2.199 898 0 X-264 0.00132 0.00068 900066 0 00063 t 00044 0 00038 0 0X133 0O9D292 4 387.844 000524 0 00262 0.00175 0 00131 0 00105 0 0X67 0- 0X75 D 00*06-53 6.474 638 0 00778 0.00389 0.00259 0 00195 000158 30313S 0 00111

! f 4 8.851 065 0 01023 0. ‘00514 0 03343 0 00257 003206- D 031716 10 887 895 0 01273 0 00686 0 03424 003338 0 001265

£ I 6 12 585 883 0 01613 0 00767 0 00604 0:03378

| I 7 14 545 769 i 0 01740 003574 0 001-0176Fest-t'eatmert 24 (6 468 281 DCW90

* - 1 .......... . i ___1 1 2 2 199 398 0 00264 QQ0132! 0 00088 0 00066 000053 0 00*044 D 0001033 i

* ~ 3 4.357.844 0 00524 0 00262 0 00175 000131 OOiiltS 003067 D 000)75

S I 4 6.474 638 0 00778 0 00389 0.00219 0 00195 0 03155 C t» l»■a | 5 6,551.0C.5 0 01028 0 00514 0.03343 f.OJ2S7 : 03206

£ 16 10 587.595 0 01273 0 03838 0 COS 187 12 585 883 ! 0 01513 103757 D 00066

Post-featmert 24 14 545 769 •.* - 1 :* j 2

© 3 2 199.893 0 00264 0 00132 0 00088 0 00068 0 03063 0 C»0»0U4 0 CCOOB

I tre |

4.357.544 ! 0 00524 0 00262 0 00175 090131 G 00*105 0 00*0*87

5 6,474.638 0 00776 0 00389 0 00259 0*0*0*195 0. C0156

§ t 6 8.561 066 0 01028 0 00514 * 03043 0 03257

| s 7 1958? 685 , 001273. OOS3S .JK «5-cst-treatmerl 24 12 MS 683 •0=91513 0 03757

T3 T. 1

t J 2

f ^ 34 2 19 95 03 ! 0 00264 6 00132 0 00088 000066 o 0 00*044

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4.2. Observations and discussion on the findings of Section 4.1.Section 4.1 defines the worst-case scenario conditions for Slice® treatment, when the total MAB for the proposed Shot Head site, of 2,800 tonnes of stock, requires treatment. This would require the feeding of 98 tonnes of feed, top- dressed with 490kg of Slice®, containing 0.98kg of EmBZ over a 7-day period. The model provided shows that, in mean, still weather tidal conditions, the mean water column concentration of EmBZ at the EQS point would not be greater than0.196ng/l, against a required EQS of 0.220ng/l; see Appendix 3. However, despite being within the required EmBZ EQS, this finding is regarded as highly conservative (i.e. it indicates a higher concentration of EmBZ at the EQS point than is likely ever to occur) for a number of reasons:-

■ For necessary reasons, this study considers only the worst case scenario. However, experience has shown that the largest of the three Slice® treatments required since 2008 on MHI's Bantry Bay sites used less than one tenth of the Slice® required for treatment in the worst case scenario modelled. This required the treatment of only 260 tonnes of stock (see Section 3.1), when the likely maximum concentration of EmBZ at the EQS point would not have been more than 0.0182ng/l, against the EQS of 0.22ng/l

• The result also assumes worst case because only still weather currents are considered in the model. In reality, winds blow at over 5.5msec'1 for more than 50% of the time in SW Ireland. This can have a considerable influence on current speeds and therefore dispersal rates, if wind speeds of 5.5msec'1 or above are sustained in one direction for any length of time.

■ The use of a mean concentration across the selected EQS box area, as defined, also makes the worst case, in that it can be reasonably assumed that EmBZ concentration would fall, from within the treatment area itself, to the perimeter of the EQS box, 100m beyond it. This is confirmed in a dispersal study, commissioned by MHI from RPS International engineering consultants for the 2011 Shot Head EIS 4. Figures 3 to 8 are abstracted from this report. The study did not model EmBZ dispersal specifically and it is not possible, without further information not available at the time of writing the present report, to apportion EmBZ loadings to the solids settlement and suspension profiles shown in these figures. However, the figures do show that solids concentration reduces by a factor of at least 90%, from its peak/s, near the centre of the EQS box area and its perimeter (outlined in red), in solids settled on the seabed (Figures 3 and 4), in solids within 1.5m of the seabed (Figures 5 and 6) and in solids suspended through the water column (Figures 7 and 8). Since EmBZ can be assumed to be evenly distributed in feed and faecal particles, the same concentration profiles will apply to EmBZ content.

4 RPS Report IBE0490/R02/NS to MHI April 2011. Settlement study; Shot Head, Bantry Bay.

The calculations used further make the worst case in that all waste feed and faecal EmBZ excreted are assumed to remain in the water column and are therefore included in the calculated EmBZ concentration at the perimeter of the EQS box. However the RPS report referred to above shows that a proportion of the EmBZ will be contained in solids which settle onto the seabed and which remain there for at least one month (see Figures 3 and 4), as a result of local current conditions. This proportion of the EmBZ load could therefore be discounted from the EmBZ concentration 24 hours post treatment, at the EQS box perimeter, as required; see Appendix 3.

The RPS document also makes the point that even directly under the pens, the accumulation depth of settled solids is low (see Figures 3 and 4; 3mm after one month at MAB), relative to other low current sites. The report considers that this is due to the low stocking density proposed for the Shot Head site (maximum of 10kg/m3, the requirement for organic production) and the large cross-sectional area of the pens. For this reason, it can be assumed that EmBZ will also be dispersed at low concentration in settled solids at the seabed and will therefore also be unlikely to have any material impact on local infauna and epifauna.

9 I

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Figure 3. Shot Head; solids sedimentation following month of greatest stocking level. Key : Red square shows limit 620m x 340m box model area.

18 2 1 3 4 18 5 1 9 8 1 9 0 1 9 2 19 <S(kilometre)

Maximum[net

mm]

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Figure 4. Shot Head; solids sedimentation during month of greatest stocking level. Key : Red square shows limit 620m x 340m box model area.

From RPS Report IBE0490/R02/NS to MHI April 2011. Settlement study: Shot Head, Bantry Bay.

(ktio

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tiej

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0 002 - 0.004 0 >01 • 0 >02 Bektv. 0 001

f .u» cpab€ct duringFigure 5. Shot Head; average solids concentration within 1.5m ot tne

the MAB month.Key : Red square shows limit 620m x 340m box model area.

190i k i l o m e t ' e i

Maximum solids

concentration m g l

| Abcv® 0 090

S M B 1 0 080 -0 090

0

Or--o

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1 o 006 -0 008

1 o 004 ■ 0 006

1 o 0 0 2 '•0 004

I 0 001 ■•0 002Eelow 0 001

Figure 6. Shot Head; maximum solids concentration within 1.5m of the seabed during the MAB month.Key : Red square shows limit 620m x 340m box model area.

From RPS Report IBE0490/R02/NS to MHI April 2011. Settlement study; Shot Head, Bantry Bay

(kilo

met

re)

n

(kilo

met

re)

19 0 kilometre i

Average solids concentration mg'!

■ 1 Above 0 393 " 0 330-0 330

0 070 - 0 330 0 300 - 0 373 6 350 - 5 060 £> 340 - 0 350 0 030 - 0 340 0 320 • 0.330 0.310-0 320 0 333 - 0 310 0 335 - 0 333 0 334 - 0 335 0 332 - 0 304 0 331 - 0 332 Belov. 0 331

igure 7. Shot Head; average solids concentration through the water column during the MAB month.Key : Red square shows limit 620m x 340m box model area.

19 0ikiicmet'e ■

Maximum solids

concentration m g l

Above 0 090 0 080 - 0 090 0 070 - 0 080

0 060 - 0 0 '0 0 050 - 0 060 0 040 - 0 060 0 030 - 0 040 0 020 - 0 030 0 0 1 0 - 0 0 3 0

0 0 0 8 - 0 0 1 0 0 006 - 0 008 0 0-04 - 0 006 0 002 - 0 004 0 001 - 0 002 Below 0 001

Figure 8. Shot Head; maximum solids concentration through the water column during the MAB month.Key : Red square shows limit 620m x 340m box model area.

From RPS Report IBE0490/R02/NS to MHI April 2011. Settlement study; Shot Head, Bantry Bay.

4.3. Loadings, dispersal and fate of Deltamethrin.With reference to Section 3.2.2, the dispersal of Deltamethrin is simpler than that for EmBZ, because it entails the dispersal of only one stream of exhausted Deltamethrin treatment, by completely flushing it out of the well tanks and into the water column, with clean water. The tanks can then be charged with a new treatment mix, ready for the next batch of fish. See SOP in Appendix 4. Individual treatments take place over a four-hourly cycle per 100 tonne batch of fish to be treated. In the worst case circumstance, treatments would be completed every four hours around the clock until the total MAB of 2,800 tonnes offish has been treated, that is, over 112 hours (4.67 days).

The Deltamethrin EQS requirement is as for EmBZ, defined as the water column concentration of Deltamethrin, 100m from the treatment site, 24 hours after treatment completion; see Appendix 3. The model used considers the dispersal of each 4-hourly flushing separately and, because well-flushing post-treatment takes only one hour, within a short treatment cycle, dispersal is considered under both neap and spring tide conditions. The neap and spring tidal prism models used are shown in Tables 7 and 8 and neap and spring tide dispersion models are shown in Tables 9 and 10. (Note that, in contrast, Slice® treatment is not a batch process; Slice treatment last 7 days however many fish are treated).

Table 7.Tidal prism model for selected box area of 620m x 340m (210,800m2); neap tide.

Parameter Notation Data Units

Notional box low water sea area A 210,800

Notional box mean low water depth D 37.10 m

Thus notional box mean low water volume V = A x D 7,820,680 m3

Mean tidal ranqe neap tide Rn 1.30 m

Thus mean neap tidal volume Pn = A x Rn 274.040 m3

Mean neap flushinq time (tidal cycles) Tn = (V + Pn) / Pn 29.54 tidal cycles

Thus mean neap flushinq time (days) Dn = T n / 2 14.77 days

Mean neap daily flushing rate litres Fnd =(V / Dn) x 1000 529.525.208 litres / day

Mean neap flushinq rate per 4 hour treatment time, litres Fn4h = Fd / f 88 254.201 litres / 4 hours

Table 8.Tidal prism model for selected box area of 620m x 340m (210,800m-); spring tide.

Parameter Notation Data Units

Notional box low water sea area A 210.800 m'

Notional box mean low water depth D 37.10 m

Thus notional box mean low water volume V = A x D 7.820.680 nr

Mean tidal range neap tide Rs 2.90 m

Thus mean neap tidal volume ps = A x Rs 611,320, nrr

Mean neap flushinq time (tidal cycles) Ts = (V + Ps) / Ps 13.79 tidal cycles

Thus mean neap flushinq time (days) n s = T s / 2 6.90 days

Mean neap daily flushing rate litres Fsd =(V / Ds) x 1000 1,133.998.600 litres / day

Mean spring flushinq per 4 hour treatment time, litres Fs4h = Fd / ( 188 999.767 litres / 4 hours

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Tables 7 and 8 calculate that, under mean neap tide and mean spring tide conditions, the EQS box is flushed with 88,254,201 litres and 188,999,767 litres of water every four hours respectively. Thus dilution of any solute in the water column is over 100% greater in spring tide than in neap tide conditions.

Tables 9 and 10 calculate the release of Deltamethrin at the end of every 4- hour treatment period. It is then dispersed progressively on a repeating four hourly cycle through the duration of 28 the treatments required to treat the entire MAB of 2,800 tonnes of fish. The bottom line of each column sums the individual dilutions of each Deltamethrin release at each four-hourly dilution step and thus shows the worst case mean dilution across the EQS box after every treatment. Finally, in the far right column, the mean dilution, 24 hours after the completion of all the treatments is given (in bold red, at the bottom right-hand corner of the tables). Both tables show that concentration of Deltamethrin gradually builds up, from the first to the last treatment and then starts to decrease in the 24-hour period after the last treatment has been flushed from the well tanks.

Tables 9 and 10 find that the worst case concentration of Deltamethrin at the EQS point would be an average of 0.04537ng/l under mean neap tide conditions and 0.02118ng/l under mean spring tide conditions, compared with an EQS for Deltamethrin of 2.00ng/l.

Since Deltamethrin does not bioaccumulate in fish and, on release into the environment, less than 10% of the release persists after 10 days, the ambient Deltamethrin concentration will decrease with time following completion of treatment, with immediate effect.

4.4. Observations and discussion on the findings of Section 4.3.Section 4.3 defines the worst-case scenario conditions for Alphamax® treatment, when the total MAB for the proposed Shot Head site, of 2,800 tonnes of stock, requires treatment. The treatment of 100 tonnes of stock (split between the two 600m3 wells in the Grip Transporter well boat), would require 120ml of Alphamax®, containing 1,200pg (1.2mg) of Deltamethrin, per tank, per 40 to 45 minute treatment, Twenty-eight, four-hourly treatment cycles, each including a 40 to 45 minute treatment, would be required to treat the entire MAB.

The model provided shows that, in mean, still weather conditions the mean water column concentration of Deltamethrin across the EQS box and therefore also at the EQS point, would not be greater than 0.04537ng/ng/l, in mean neap tide conditions, and 0.02118ng/l, in mean spring tide conditions. This compares favourably with a required EQS of 0.220ng/l; see Appendix 3. However, despite being, at most, no more than 2.5% of the Deltamethrin EQS, both the concentrations calculated are regarded as highly conservative for a number ofreasons:-

■ The result assumes worst case because only still weather currents are considered in the model. In reality, winds blow at over 5.5msec'1 for more than 50% of the time in SW Ireland. This can have a considerable influence on current speeds and therefore dispersal rates, if wind speeds of 5.5msec"1 or above are sustained in one direction for any length of time.

■ The use of a mean concentration across the selected EQS box area, as defined, also makes the worst case, in that it can be reasonably assumed that Deltamethrin concentration would fall, from within the treatment area itself, to the perimeter of the EQS box, 100m beyond it. This is confirmed in a dispersal study, commissioned by MHI from RPS International engineering consultants for the 2011 Shot Head EIS 5, used to support a similar view regarding the dispersal of EmBZ in the water column in Section 4.2; see also Figures 7 and 8.

■ It should also be noted that that there has never been a need for a Alphamax® treatment (containing the active ingredient Deltamethrin) on MHI sites in Bantry Bay in the 35 year history of the operation of sites in the area.

Section 5.Conclusions.

Marine Harvest Ireland (MHI) applied to the Aquaculture and Foreshore Management Division (AFMD) of the Department of Agriculture, Food and Marine (DAFM) for an Aquaculture Licence and a Foreshore Licence, in the name of Bradan Fanad Teoranta, to operate a marine salmon farm at Shot Head, Bantry Bay, in May 2011.

The Marine Institute (Ml) were required by DAFM to review the application and EIS towards the end of 2013, resulting in the issuing of a report from the Ml in January 2014. This was followed up by a request for additional information on the Shot Head application from DAFM to MHI, on 10th February 2014,

The information required concerns MHI's intended methods of application and likely quantity and frequency of the discharge to the sea of sea lice treatments, Slice® (active ingredient Emamectin Benzoate; EmBZ) and Alphamax® (active ingredient Deltamethrin). These are defined as dangerous substances, under SI 466 2008, the European Communities (Control of Dangerous Substances in Aquacutture) Regulations 2008. In addition, confirmation was sought of the compliance of likely releases of EmBZ and Deltamethrin to the marine environment with Environmental Quality Standards (EQS's) set by SI 466, that they should not exceed water column

5 RPS Report IBE0490/R02/NS to MHI April 2011. Settlement study; Shot Head, Bantry Bay.

concentrations of 0.22ng/l and 2.00ng/l respectively at the EQS point, 24 hours after the completion of a sea lice treatment and 100m from the treatment site.

In common with all salmon farm sites in the country, MHI's existing sites in Bantry Bay have been subject to the National Sea Lice monitoring program since 1991, under which sites are monitored for sea lice levels 14 times per annum, which includes monitoring twice per month between March and May, when wild salmonid smolts are migrating seawards.

The monitoring record for 2008 to 2013 shows that sea lice levels on MHI's Bantry Bay sites have remained extremely low. In consequence, very few treatments have been required. Much the same applies to other sites in the southwest of Ireland, both belonging to MHI and to other operators in the area. In fact there have only been three Slice® treatments since 2008, the largest of these requiring 45kg Slice®, to treat 260 tonnes of recently transferred SO stock, in December 2008. There have also been three Hydrogen Peroxide (H2O2) lice treatments in Bantry Bay in the same period but, since the breakdown products of H20 2 are oxygen and water only, this product is not regarded as dangerous and is not subject to EQS. There has never been an Alphamax® treatment on MHI sites in Bantry Bay.

This report only considers the likely impact of worst case sea lice treatments at the EQS point, using EmBZ and Deltamethrin. This situation would arise if the entire proposed Maximum Allowable Biomass (MAB) of fish on the proposed Shot Head site, of 2,800 tonnes of stock, required treatment for sea lice.

This report calculates that, if such a Slice® treatment were required, 92.5 tonnes of medicated feed, containing 925mg of EmBZ, would be fed to the stock over the 7-day treatment period. This would result in the release of EmBZ to the marine environment at Shot Head via three different pathways. The report estimates that a total of 27.5mg of the total EmBZ load would be released immediately in waste feed, 89.7mg would be released almost immediately in faeces and the balance of 807.5mg would be retained as body load in the fish (giving them lice protection for ten or more weeks), to be steadily released on an exponential excretion curve, such that 50% of the load will have been excreted after 36 days. The equations are developed for these releases on a daily basis following each day's feeding of the stock. Each day's EmBZ releases are then dispersed using a tidal prism box model, to give an average concentration for EmBZ at the EQS point, that is 24 hours after the completion of the 7-day treatment, in an area of 620m x 340m, or 210,800m2, the perimeter of which lies 100m beyond the treatment area.

It is thus calculated that the mean EmBZ concentration under mean tidal conditions will be 0.196ng/l, against a required EQS of 0.220ng/l.

Treatment with Alphamax® (active ingredient Deltamethrin) at Shot Head would be carried out in the well tanks of the well boat MV Grip Transporter, which has two 600m3

wells. The two wells together are sufficient to hold 100 tonnes of fish for treatment, requiring 120ml of Alphamax® per tank, containing 1.2mg of Deltamethrin. The treatment lasts for 40-45 minutes, within a cycle time for the filling and emptying of the wells with water and fish, which lasts 4 hours per treatment. Treatments are carried out on a 24-hour day basis until complete. Thus, to treat the entire proposed MAB of the Shot Head site, of 2,800 tonnes of fish, would require 28 separate 4-hour treatment cycles and take 112 hours. This would use and discharge 2.4mg of Deltamethrin in the two wells combined, every four hours, or 67.2mg Deltamethrin for the 28 treatments required for the total MAB, over 112 hours.

Since the flushing of the wells takes no more than one hour, within a treatment cycle of 4 hours, the dispersal of Deltamethrin is considered under both mean neap and mean spring tide conditions, using two separate tidal prism models. The flushing from each four-hourly treatment cycle is dispersed separately over the 112-hour treatment period and the dispersal model is continued until the EQS point, 24 hours after the completion of treatment, is reached.

The model projects that the mean dilution of Deltamethrin concentration through the 620m x 340m box, at the EQS point, would be 0.04537ng/l under mean neap tide conditions and 0.02118ng/l under mean spring tide conditions, compared with the EQS set for Deltamethrin of 2.00ng/l.

The report observes that, although the mean concentrations for both EmBZ and Deltamethrin at the EQS point are found to be below the set EQS's for these two substances, the calculations are worst case and highly conservative. In consequence, the actual values, 24 hours post treatment, 100m from the treatment site, are likely to be much lower than predicted, for a variety of reasons. Amongst these are the fact that, rather than a mean value applying across the selected box area, a concentration gradient will apply. Other studies are cited that suggest that the concentration at the EQS point will be at least 90% less than the concentration close to the centre of the treatment area. In addition, only still weather conditions are considered in the calculations.

It should also be noted that it has never proved necessary to treat more than one tenth of the worst case MAB treatment modelled in this exercise in Bantry Bay, that lice treatments are rarely required in Bantry Bay, that no lice treatments have been required on MHI Bantry Bay stocks in the last two years and that, for some generations of stock, no lice treatments are required at all.

pptotJOfl by Marine • vai Ireland for a Sain-.n Farm Development at ho* Head Banlty Bay HI. Cork fi( TBSS55- Additional infcrtnatwn

Appendices

Appendix 1Request for further information

1. Letter from K. Hodnett, DAFM, to J Feenstra, MHI.

Mr Jan Fccnstra Marine Harvest Ireland K.indrum,Fanail.Letterkcimv,Co, Donegal

Agriculture,Food and the Marine

Talm haiochta, Bia agus M ara

sent by registered uo

Our Ref: - 15 555

10 February 2014

RE: T5/555 ~ Aquaculture/Foreshore Licence Application, Shot Head, Co. Cork Request for Further Information

Dear Mr Fccnstra,

I am to refer to the above application and enclose lor your attention a copy of a report received fiom the Marine Institute concerning the Environmental Impact Statement (FIS) submitted by Marine Harvest Ireland in support of the above mentioned application.

As will be seen, this report requires further infimnalion to be supplied by the applicant The specific information required is set out in the attached note.

This request lor furlhet information in relation to the FIS is being made undei the provisions of Regulations 12(2) of ST No. 2.46 1998 - Aquaculture (licence Application) Regulations. IhdS as amended and Section !9B(2)o! the Foreshore Act 1933 as amended

Please note that Regulation 12 of SI 236 1968 Aquaculture (Licence Application)Regulations. !66Sas amended and Section I6B(3) of the Foieshore Act 193 as amended inicl.'.t o i :o publication of this further information will also apply. It is important to also note that an instruction in relation to the publication under the terms of Regulation 12 of Si236 1665 Aquaculture (Licence Application) Regulations. 1998 as amended and Section 1913(31 of the Foreshore Act 1953 as amended will be issued at a later stage.

A tesjxMtse ttorn M il! tn :cspcct ol the attached tepoil should t>e toivvardcd to tins Di\ ision « ithin 4 wecLs of the date of this letter.

YaWS Sinceielv,

Kevin Hodnett

Aquaculture & Foreshore Management Division Department o f Agriculture, Food and the Marine National Seafood Centre Clonakiliv Co Cork

Tel: 023 8S59503

Appendix 2

Request for further information document.

Marine Harvest Ireland Application for a Salmon Farm Development in Bantry Bay (Shot Head)

Additional Information.

Marine Harvest Ireland Application fo r a Salmon Farm Development in Bantry Bay i Shot Headi - Additional information

ContextThe European Communities (C ontro l of Dangerous Substances in Aquaculture) Regulations 2008 (SI 466 o f 2008) was introduced fo r the purpose of giving effect to the Dangerous Substances Directive (2006/11/EC ). Habitats Directive (92/43/EEC) and W ater Framework Directive (2000/60/EC), so far as these Directives relate to the discharge of dangerous substances to the marine environment from aquaculture activities.

SI 466 of 2008 states, inter alia:Regulation 3(1):/

A licensing authority shallnot grant an aquaculture k en ce .f in the opinion of the authority- fa/ the applicant s unabieto comply with limits on the quantity and concentration of a

dangeroussubstancethat m aybe discharged, fbj the applicant's unabieto comply with required emission standards,(c) it is necessary in order to secure compliance with environmentalquaOty objectives or

standards,(dj it is necessaryfbr the protection of human health, plant health, animalheafth or

welfare, or the environment or(e) it is necessary, ancillary or supplementary for an act of the institutions of the

European Communities (including an act cited in the preamble to these Regulations) ro have full effect

Regulation 44(1) requires an application fo r an aquaculture licence to:

(a) identify'any dangeroussubstance which is intended to be discharged,(b) indicate the quantity of the discharge of each dangeroussubstance,fc) indicate the frequency of the discharge of each a'angeroussubstance,and I'd) demonstrate that the intended discharge will not have a deleterious effect on the

environmental quality objectives for the receiving waters

4(2) it is sufficient compliance with paragraph ( l) to—(a) address the matters raised in that paragraph in an Environmental impact

Statement submitted as part of an application, and fbj demonstrate that the use of a dangerous substances subject to an equivalent level

of statutory control as provided for in these Regulations

Regulation 7A licensing authority may require an applicant or licensee to submitplans or other particutorsin relation to the activity to which the application or aquaculturelicence relates, or to the emission or discharge o f a dangeroussubstancedue to that activity as the licensing authority considers necessary for the purpose of determining an application..........

Additional Information RequiredThe information provided in the EIS is sufficient to understand the type and nature of the dangerous substances intendedfor use as sea lice treatments and their intended method of application. There is, however, insufficient informationMata on the likely quantity and frequency of discharge of these substances. Furthermore, the EIS has not adequately demonstrated compliance with the EQS fo r these substances1, as is required.

In order to ensure that the applicant is in compliance with the requirements of SI 466 2008, and in order to allow the Minister to make a determination on the application, the Marine Institute recommends that DAFM request the applicant to provide:

I. Information on the:a) Estimated quantity o f the discharge of each dangerous substance intended fo r use at

the site, andb) Likely frequency of the discharge of each dangerous substance intendedfor use at

the site.

II. Data and information that would demonstrate compliance with the Environmental Quality Standards (EQS) which apply to each dangerous substance intendedfor use at the site. This may be based on the output of appropriate models o r other relevant methodology.

This additional information should be also sufficientto allow a more complete assessment of the impact of dangerous substances on benthic fauna, commercial fish and shellfish.

Note -The information required at fa) and lb) above could be based, at (east in part; on the applicants experience of the use and discharge of dangerous substance at other simitar Been sed sites— or other sources; as relevant

: A v a i l a b t e 3 t

f c t t s : t v e r c z o y . i - a n ^ a c u g r i t i o i . t i ib a i i - a ; . a ^ a r i i 1 r j j ^ g > f a i t ; j r a c i 3 L a s - a c i 3 : t i n p l a n - S L m i o n f c t a ;

v vT -ltrT ^g aE aayd M i:b -t3D :a io iT ? :tiy -s 2 D S D £ Q S D a rtS 'h i2 023-021 ti.a H

Appendix 3.Request for further information

Environmental Quality Standards for sea lice treatments.

In accordance with SI 466 2008 European Communities (Control of Dangerous Substances in Aquaculture) Regulations 2008.

Ill accordance with the EUROPEAN COMMUNITIES (CONTROL OF DANGEROUS SUBSTANCES IN AQUACULTURE) REGULATIONS 2008 the following Environmental Quality Standards apply to substances used in the treatment marine fmfish during the operation of Aquaculture facility on the Foreshore in Ireland,

The following standards shall apply 24 hours post treatment at 100m from siteC'vpermedirm (Excis) 0.5 ng/1Teflubenzuron 30 ng 1Emamectm benzoate (Slice) 0.22 ng 1Alphamax (Deltamethnn) 2 ng 1Azamethiphos 150 ng'l

Version 1.0These standards are subject to revision from time to time.6 December 2008

Appendix 4.

Marine Harvest Ireland Special Operating Procedures (SOP's)

relating to sea lice treatment.

1. SOP 25450 Version 002. Lice monitoring.

2. SOP 26077 Version 002. Sea lice treatment with Slice®.

3. SOP 29142 Version 004. Alphamax® treatment in well boats.

4. SOP 30553 Version 002. Hydrogen peroxide treatment in tarpaulin.

5. SOP 23392 Version 002. Hydrogen peroxide lice treatment in well boat.

6. SOP 22961 Version 001. Sea lice treatment rotation.

ID: 25450 Version no.: 002

Lice Monitoring Marine Harvest IrelandResponsible organization: Ire la n d / M a rin e P roduction / Fish H e a lthDocum ent category: P rocedures Last changed: 14.06.2013 { S inead D o h e rty )Latest audit: 14.06.2013 N ext audit: 02.06.2014Approved: APPROVED 14.06.2013 ( M cM anus, C a th e rin e )

Lice Monitoring:

1. Scope:

Sea lice (Lepoeopfitheirus salmonis, Cahgus elongatus) present the most significant health challenge to Atlantic salmon It is imperative that recruitment of lice onto our stocks is carefully monitored and used to determine the optimum time to take corrective action. This procedure applies to all stocks mder the control of Marine Harvest Ireland

2. Records:

Record results on the Weekly Lice Monitoring & Gill Score sheet (TQM ID 25447) or results can be recorded on Sample Weighing sheet (TQM ID 25452) if monitonng is earned out during sample weighing. Return records to relevant technical office.Ail counts and in particular, those from the last week of each month for all sites, must be reported to the Technical Manager

3. Sampling Frequency:

A minimum of 3 pens per site must be sampled weekly. A minimum of 10 fish per pen must be sampled.

4. Procedure:

Hand net 3 fish at a time onto the MS222 anaesthetic bath, sampling a total of 10 fish per pen. After the fish have been anesthetised, carefully lift one out, count the total numbers of juveniles, mobile, and gravid lice The attached identification card may be usedReturn fish directly into its original pen to allow full recovery. Repeat for all fish sampled

5. Treatment Trigger:

When average numbers of gravid lice reach 0.2 per fish or total lice numbers exceed 5, a treatment is required. For organic production, this is subject to permission from the organic certifying bodies Where possiWe/relevanf, site managers within the same bay must co-ordinate treatments within the same week in order to reduce re-infection pressure on fish.

6. HES Precautions:

Wear appropriate PPE. including gloves when handling anesthetised fish Observe manual handling procedures. Observe withdrawal for MS222.

7. Safety risk assessment:

Safety Risk Assessment: OPERATING CONDITIONS: Normal

Work Operation: LICE COUNTS

Staff Required for Task: 2

24.06.bC13 1 2 :37 :33 Page t of 2This docum ent is not approved in a printed version. Approved version only ex ists eiectromicaHy.

ID: 26077 Version no.: 002Sea lice treatment with Slice Marine Harvest IrelandR espo nsib le o rg a n iz a tio n : Ireland / M arine Production / Fish HealthD o c u m en t c a te g o ry : Procedures Last ch an g ed : 31 .05 .2011 ( McManus, Catherine )L a te s t a u d it: Not set N e x t a u d it: 09 .0 7 .20 1 0A pp ro ved :___________APPROVED 31 .0 5 .20 1 1 ( McManus, Catherine )__________________________

Sea lice treatment with Slice®

1, Pre-treatment planning and preparations:

All treatm ents against sea lice should be pre-planned as part of the site/area Veterinary Health Plan and in coordination with other sites within the m anagem ent area/neighbourhood

If there are indications of increased tolerance to Em am ectin benzoate (from previous treatm ents) or if the last 2 treatm ents on site w ere with Slice®, conduct a bioassay to determ ine sensitivity T he result of the bioassay should be used by the V eterinary advisor and Technical M anager to guide the decision as to the correct treatm ent

For 4 w eeks prior to treatm ent it is recom m ended to com plim ent the diet with BioMos (@4kg / 1 f e e d ) r

2. Quantity of Slice® and medicated feed required;

2.1 U se upper-end estim ate of num ber and upper-end estim ate of average liveweight to calculate biomass Depending on the confidence in fish counting and weighing procedures, it m ay be prudent to add an additional am ount e g -1 0 % to this biomass figure 2

2 2 To allow for growth, the weight should be projected forward to the last day o f the intended treatm ent penod 3

2 .3 R eview current feeding practice and appetite with the site m anager on a case- bv-case basis, decide on quantity of feed and the feed ng strategy to be used 4

2 .4 Optimal distribution is achieved when S lice® m edicated feed constitutes 100% of the daily ration and is fed to daily satiation.

2 5 Consider an Alternate Day M edication feeding strategy 5

2 .6 Every effort should be m ade to provide ca. 10% of the m edicated feed by hand around edges of pens for less dom inant feeders.

2 .7 Calculate the required inclusion rate o f S lice© into the feed s

2 .8 Avoid m ajor changes in m edicated base diet composition from normal feed composition. If possible, drop a pellet size for treatm ent of growers and lower pigment level in the m edicated base d ie t7

2 .9 Ensure S lic e® is top-coated onto m edicated base diet

2 .1 0 Conduct a sea I ce count a m axim um of 7 days prior to treatm ent with a target of 2 days prior (R ef. procedure "11.01.03 S ea lice treatm ent efficacy- m onitoring1 )

t4 .O S.2at3 n2::03s34 Page 1 of 4

Tnis document s net approved n a printed version. Approved version only exists electronically.

Marine Harvest IrelandID: 26077 Version no.: 002

Sea lice treatment with Slice

R espo nsib le o rg a n iz a tio n : Ireland / Manne Production f Ftsh HealthD o c u m en t c a te g o ry : Procedures Last changed : 3 1 .0 5 .2011 ( McManus, Catherine )L a te s t a u d it: Not set N e x t a u d it: 0 9 .0 7 .2010A p p ro v e d :___________APPROVED 3 1 .0 5 .2011 ( McManus, Catherine )__________________________

2.11 Moribund or non-feeding fish should be removed prior to treatment where possible.

2.12 Ensure appetite is not compromised before starting the treatment. In addition, it is recommended to screen for pathogens which may compromise appetite (eg SAV) dunng known disease nsk periods.

2.13 Withhold feed from the population for 24hr before treatment.

3. Treatment:

3.1 Slice® medicated diet will be administered daily at the prescribed ration for 7 days, targeting a nominal dose of 50pg EmB / kg bw1 / day. Alternatively, use Alternate Day Medicating if appropriate (ensuring the same total Slice® dose over 7 days) Any deviation from this should be at the discretion of the prescribing veterinanan and whatever change is made should be recorded.

3 2 Treat all fish on the site simultaneously.

3 3 Slice® medicated feed should be the only feed given dunng the treatment period ie 100% of the daily ration No un-medicated top-ups should be provided during the treatment.

3 4 Use a feeding regime that maximises feed availability to and within thepopulation. Create a feeding opportunity for as many fish as possible when Slice® medicated feed is being fed - spread in time and space.

3.5 Simultaneously hand feed with ca. 10% of the daily ration for each cage, focusing on delivery around the cage edges. If no fish appear to be taking this feed, incorporate this amount of feed into the daily ration.

3.6 Prevent wastage of medicated feed (do not overfeed) use cameras where available to monitor feed intake.

3 7 Monitor feeding response and behaviour throughout the treatment. Anysuspect adverse effects dunng the treatment should be indicated to the fish health responsible person.

3 8 Take a sample of Slice® medicated feed and archive (ideally frozen) for future analysis to corroborate nominal dose in the d ie t8 3 4

3 9 Prior to handling medicated feed, staff must wear gloves, overalls and dustmasks

4. Post-treatment and follow-up:

4 1 For 2 weeks post-treatment it is recommended to compliment the diet withBioMos (@ 4kg / 1 feed).

14.06.2013 12:03:24 Page 2 of 4

This crorc-merrt is not approved in a printed version. Approved vers on only exists eiecTronncaIly.

Marine Harvest IrelandID: 26077 Version no.: 002

Sea lice treatment with Slice

R espo nsib le o rg a n iz a tio n : Ireland / Marine Production / Fish HealthD o c u m en t c a te g o ry : Procedures Last ch an g ed : 31 .05 .2011 ( McManus. Catherine )L a te s t a u d it: Not set N e x t a u d it: 0 9 .0 7 .2010A pp ro ved : APPROVED 31 .05 .2011 ( McManus, Catherine )

4.2 Flesh samples from 5 fish should be taken 24hr post-treatment and frozen for future analysis it required 9

4.3 Refer to sea lice counts at 2, 4 and 8 weeks post-treatment to determine treatment efficacy (Ref. procedure “Sea lice treatment efficacy").

4.4 Analysis of feed and flesh samples will be undertaken if there are indications of reduced efficacy of treatment (Ref. procedure "Sub-optimal treatment effect follow-up").

4.5 If efficacy is not as desired w ithin 4 weeks, this warrants immediate use of an alternative therapy. By 2 weeks post-treatment there should be a reduction in numbers and a judgement should be made as to whether a follow up treatment Is required at 2-3 weeks post-treatment.

5. Additional information:

References;

( 1 ) B iq M o s increases epidermal mucus thereby reducing new lice settlement. BioMos also enhances gut integnty, resulting in higher EmB flesh levels

(2) In doing so the veterinarian is neither suggesting nor justifying an excss in biomass over and above reported figures but is simply recognizing the limitations of technology to produce a biomass figure that is 100% accurate all the time

(3) Fish should grow significantly between the day feed was ordered and the time of administration of the medicated feed. They will continue to grow significantly for the 7 day- duration of the course

(4) Look at the following criteria: Are fish being fed in constant pulses of feed or n discreet meals? If so how many meals are currently being provided At the end of the day do fish remain hungry or do they seem satiated well before the end of the day. Is there any foreseeable reason why appetite may change before the medicated feed arrives, e g. lighting regimes, imminent grading, changing temperature?

(5) This strategy may be appropriate if appetite seems moderate to poor or if there is a concern that some fish in the population are disproportionately nappetan: and others are feeding normally or well. Alternate Day Medication counteracts disproportionate consumption of medicated feed. (Note: The medc ne amount provided ever a 7 day period remains the same total dose calculated above and relates only- to biomass. This is not an over-dose or under dose). Starve fish on days 0, 2, 4, 6 and provide medicated feed -on days 1,3 , 5, 7 of the 7-day course. Through being starved on day 0, all fish should be provided with as much feed as they will take comfortably on day 1, without wastage. This principle follows for days 3, 5 and 7. Fish should feed well and wfl probably take more than a single day's ration on that day, possibly an extra 20-50%. The judgement of the site manager is cnucsal to determine this.

L-4.06,2'313 12r.€l3s34 Page 3 c> 4

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Marine Harvest IrelandIDs 26077 Version no,: 002Se a lice treatm ent w ith S lice

R espo ns ib le o rg a n iz a tio n : Ire land / M arine Production / Fish HealthD o c u m e n t c a te g o ry : Procedures Last ch an g ed : 31 .05 .2011 ( McManus. Catherine )L a te s t a u d it: Not set N e x t a u d it: 09 .0 7 .20 1 0A p p ro v e d : APPROVED 3 1 .0 5 .20 1 1 ( McManus, Catherine )

(6) Some feed mills only provide a limited number of inclusion rales however they should within reason be able to supply inclusion rates appropriate to the situation, e g in 0.5kg/t increments

Exam ple:• Upper-end estimate of numbers x upper-end estimate of average weight = 940t

biomass.• Projecting growth over the 7 day treatment period = 1Q10t.• Judgement call, considering time since last sample weighing, increase biomass

estimate = 1100t final biomass.• Slice required for 11001 (targeting a standard dose of 50pg EmB / kg bwt / day) =

192.5kg• Amount of feed for total course = 601 (site manager and vet’s judgement)• Inclusion rate = 3.2 kg Slice / ton feed.• Feed mill may provide 3.5 kg/t or possibly only 5kg/t inclusion rate and amount of

feed required may need to be adjusted downwards to account for this.

(7) Dropping a pellet size increases significantly the surface area of pellets allowing for better mixing of Slice onto the feed This also increases the number of pellets within a defined volume of feed, thereby improving feed availability and reducing heterogeneity of medicine uptake. Lowering pigment levels for 7 days represents a cost saving and will not measurably affect pigmentation

(8) It is recommended to take 3 separate samples x 500g

(9) ISPAH currently pay for the analysis on 5 fish. More than 5 fish would entail additional cost for MH. It is envisaged that non-lethal plasma sampling will soon replace the need for the taking of lethal flesh samples. Method validation expected end 2010

M .D U 0 1 3 12:03:34 Page 4 or 4

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ID : 29142 Version no.: 004A lp h a m a x Bath T reatm ent for W ell boats Marine Harvest IrelandR esponsib le o rg a n iza tio n : Ireland / Marine Production / Fish HealthD ocum en t c a te g o ry : Procedures Last ch an g ed : 1 9 .0 2 .2014 { McManus, Catherine )L a te s t a u d it: 19 .02 .2014 N e x t a u d it: Not setA pproved: APPROVED 1 9 .02 .2014 ( McManus, Catherine )

Alphamax Bath Treatment for Well boats:

1. Scope:

The following procedure describes the bathing method for Alphamax lice treatment using well boats.

2. Responsibility:

It is the responsibility of the Marine Operations Manager to ensure that site Managers follow this procedure as described

3. When to Treat:

3.1 When the numbers of ovigerous female lice reaches an average of 0 2 per fish. The Marine Operations Manager and Veterinary Consultant must be informed of intention and reason for treatment and the Veterinary advisor must issue a written direction,

3 2 Fish must be starved for at least 24 hours prior to treatment.

3.3 In organic stocks, permission must be obtained from the organic certifyng bodies before treatments may be carried out.

4. Storage and Issue of Therapeutics:

The Veterinary advisor and the Marine Purchase Manager is responsible for storage and issue of Alphamax. All transactions relating to the ordering, storage and issue of Alphamax are held by the Marine Purchasing Manager in Donegal and the Biological Performance Managers m Mayo, Galway and Cork

5. Dosage:

The delousing should be performed in a well-boat to ensure proper control of the treatment volume and the treatment dosage, in addition to reduce the amount of Alpha Max used and the environmental exposure.

Treatment dose: 0.2 ml Alpha Max pr. m3 (1,000 I) sea water in the treatment unit. This corresponds to 2 microgram Deltamethria litre sea water

5.2 Treatment volume for the Grip Transporter Well-boat:

The dosage is calculated according to the actual volume of the treatment unit The dose rate for the Grip Transporter well boat is calculated as follows:

Double well capacity = 1,200m3Thus 1,200 x 0 2ml of Alphamax = 240ml Alphamax required (Active ingredient = 2 4ml Deltamethrin).19.02 .2014 17:05:42 " P a g e 1 o f 3

This dccunrreni is ro t approved in a printed version. Approved verson only exists electronically.

ID : 29142 Version no.: 004A tpham ax B ath T reatm ent for W ell boats Marine Harvest IrelandR esponsib le o rg a n iz a tio n : Ite land / Manne Production / Fish HealthD o c u m en t c a te g o ry : Procedures L as t c h a n g e d : 19 .02 .2014 ( McManus, Catherine )L a te s t a u d it: 19 .02 .2014 N e x t a u d it: Not setA pproved : APPROVED 19 .0 2 .20 1 4 ( McManus, Catherine )

Maximum biomass treated per double well = 100 tons of fish Treatment period: 45 minutes

6. Advice on correct Administration:

6.1 Shake the bottle well before use. Calculate the volume of the treatment unit and the Alpha Max dose. Use a suitable container and dilute the calculated quantity of Alpha Max in seawater. Diluting the product in a large volume of seawater will ensure better dispersion and thereby the efficacy of the treatment.

6.2 After a short period of stimng, the diluted solution is spread evenly in the treatment unit. It is recommended to use a pump with low or moderate pressure to further improve an even dispersion.

6.3 Do not disperse under high pressure as this may cause atomising and/or foaming.

6 4 All fish should be oxygenated during treatment. Ensure that the oxygen level is above 7mg/l before the treatment is initiated and that it is kept above 7 mg/l during the entire duration of the treatment.

6.5 At water temperature below 6 °C. the product’s safety margin is reduced. Extra precautionary measures should be exercised if treatments are performed at low water temperatures.

6.6 To remove the treatment bath from wells, flush clean seawater through both wells on the Grip Transporter for a period of 15 minutes. Total flushing volume is approximately 1,200m3 Note: Approximate duration of each bath treatment from loading of fish to flushing of wells is 3 5 hours

7 Records and Reporting:

7 1 Record oxygen levels and water temperature during treatment cn the treatment recordsheet in addition to volumes of treatment compound used per well boat load and batch numbers. These records must be ava.lable for inspection by the relevant Government Departments A copy of the record format is attached to this procedure.

7.2 Copies of all treatments in addition to pre and post treatment lice counts must be forwarded to the Technical Manager for efficacy assessment.

8 HES Risk Assessment

Work Operation: A tpham ax B a th tre a tm e n t

Staff Required for Task: 3 OPERATING CONDITIONS: Normal

Risk Key: 1 - 3 46 — 9

Low Risk Medium Risk High Risk

19.02.2014 17:05:42 Page 2 of 1

T'nis document is ra t approved in a printed version. Approved version only exists electronically.

Responsible organization: Ire la n d / M arin e Production / Fish H ealthDocument category: P rocedures Last changed: 0 8 .1 0 .2 0 1 2 ( M cM anus, C a the rine )Latest audit: N o t set Next audit: N o t setApproved:__________APPROVED 0 8 .1 0 .2 0 1 2 ( M cM anus, C a the rine )

ID: 30553 Version no.: 002

X a S Pe'°Xide Trea‘"’e"t B P Marine Harvest Ireland

Hydrogen Peroxide Treatment in Tarpaulin:

1. Scope:

The following procedure describes the bathing method for lice or amoebic gill disease (AGD) treatment withHydrogen Peroxide using a tarpaulin.

2. When to treat:

a. When the numbers of ovigerous female lice reaches an average of 0.2 pa fish.b. When amoeba levels reach significant levels on gills and a treatment is recommended by veterinarian

(gill scores may vary)c Peroxide should be diluted once the seawater temperature exceeds 13°C

3. Dilution and Concentration:

Depending on sea water temperature, tarpaulin capacity and volume of fish in the selected pen, concentrationsand dilution rates may vary The attached tables are an approximate guide to achieving desired ppm's in atarpaulin of 36Q0m3 or a wellboat of 1200m3 (600m3 in each well) during a treatment

4. Preparation:

i. Load required number of tanks onto deck of work boat and fill from ISO tank or IBC's. Connect all tanks to stainless steel manifold, which is connected to discharge pumps Fill required amount of freshwater (if necessary) into each tank and top up with H;0; If diluting, freshwater must be added to tanks first NEVER add water to peroxide

ii. Lift oxygen diffuser and bank onto work boat with approprate slings

iii. Onto another separate work boat, the tarpaulin in its bag s loaded by means of crane. The tarpaum hanger, centre weight and 2 side weights are also loaded

v. Moor boat with tarpaulin to selected pen arid ensure beat is pos t cried up current.

v. To prepare the net, ensure net is pulled up to a depth of 1m and secured to stanefrons with slack netting tied up to stanchion also Ensure fish are ret experiencing any undue stress.

vi. Oxygen diffusion pipes are deployed into pen, and oxygen is administered at a level to ensure >90% saturation The oxygen system should be powered on before deployment to prevent salt water entering hoses and eventually causing salt residue buTd up and damage.

vii. At this stage the H-CNdischarge hoses are also earned across the pen bv a diver

5. Tarpaulin Deployment

i. 8 ropes are taken around the pen from vessel hiding tarpaulin, and secured to each comer of pen.

H4 .Q6.2013 09 :31:23 Page 1 of 5This document is not approved in a printed versis” . Approved vers on f eat sts efecbOTKally-

3D: 30553 Version no.: 002

Hydrogen Peroxide Treatment inTarpaulin Marine Harvest IrelandResponsible organization: I re la n d / M a rin e P roduction / Fish H e a lthDocum ent category: P rocedures Last changed: 0 8 .1 0 .2 0 1 2 ( M cM anus, C a th e rin e )Latest audit: N o t set N ext audit: N o t setA p p r o v e d :____________ APPROVED 0 8 .1 0 .2 0 1 2 ( M cM a n u s , C a th e rin e )_____________________________

ii Tarpaulin is prepared on deck with centre weight attached to bottom lifting eye, and tarpaulin retrieving rope attached to same lifting eye.

iii. The top 16 numbered loops on tarpaulin are sorted and hung onto apparatus for hanging and lifting tarpaulin.

iv. Lift the centre weighbtarpaulin with crane and lower gently Into water between pen pontoon and net.Lift the remaining sections using slings gradually, until the mouth of the tarpaulin is 1 m above the surface, keeping as low as possible to the deck at all times to avoid catching wind

v The 8 comer ropes are connected to the matching 8 eyes on the tarpaulin 2 weights are connected to the first 2 eyes to be dropped from the hanger.

vi. All slack must be taken up on the 8 ropes at each comer of pen simultaneously.

vii Release the eyes from the hanger, 1 by 1, as the slack is being taken up. Once all eyes have been released, slowly Wnch up all 8 comers and tie off the tarpaulin just above water level

viii All other water ties are tied up similarly, until the tarpaulin is sealed.

6. Bath Treatment:

i. Once tarpaulin has been sealed and filled with water, the valves are opened on the holding tanks, and pumps are started to release peroxide into the pen

II. When the tanks have been emptied, swf ch off pumps and begin timing the duration of the treatment. Fish should be exposed for a minimum of 15 minutes and up to 25 minutes, dependant on reaction of fish.

iii Once time has lapsed, the tarpaulin is released on the opposite side of the pen first, and dropped at each section, as quickly as possible

iv When tarpaulin has been fully released, start winching up the retrieving rope to the surface Disconnect centre weight and begin to lift tarpaulin using appropriate lifting slings. As this is being earned out, drop the net in the pen slowly back to original state

v Once tarpauim is cn deck, lift out oxygen and peroxide diffusion pipes, stowing safely on deck of boat

7. Records & Reporting

Details of treatment are recorded on the Tarpaulin Treatment Log'. It is the responsibility of the site manager to ensure aB records are completed and signed.All records are stored in the relevant technical office.

8. HES

Ensure appropriate PPE is worn by all operators on site Eye protection is imperative Approved chemcal suits should be worn by those in direct contact with IBCs & ISO s.

All slings must be certified and apprepnate for the process Only use IBC's with steel lifting frames

14.06.2013 09:31:23 Page 2 of 6This document is "ot approved in a printed version. Approved vet se n or.'y exists electronically.

ID: 30553 Version no.: 002

Hydrogen Peroxide Treatment inTarpaulin Marine Harvest IrelandResponsible organization: I re la n d / M a rin e Production / Fish H e a lthDocum ent category: P rocedures Last changed: 0 8 .1 0 .2 0 1 2 ( M cM anus, C a th e rin e )Latest audit: N o t s e t N ext audit: N o t setApproved: APPROVED 0 8 .1 0 .2 0 1 2 ( M cM a n u s , C a th e rin e )

Safety data sheets, emergency showers & eye wash units must be available at all times

9. Guide for use of Hydrogen Peroxide in Wellboat and Tarpualin:

CONCENTRATION GUIDE FOR USE OF HYDROGEN PEROXIDE

Grip Transporter Well Capacity - 600m3|Tonnes Fish| Cubic M Peroxide | ppm |

10 i 59320 i 60330 i 61440 i 62550 i 63660 i 648

|Tonnes Fish| Cubic M Peroxide | ppm j10 2 118620 2 120730 2 122840 2 125050 2 127360 2 1296

Tarpaulin Capacity ■ 3600m31 Tonnes Fish| Cubic M Peroxide | ppm

40 8 78780 8 795120 8 805160 8 814200 8 824240 8 833280 8 843

|Tonnes Hsh| Cubic M Peroxide | ppm i40 12 118080 12 1193120 12 1207160 12 1221200 12 1235240 12 1250280 12 1265

| Tonnes Fish | Cubic M Peroxide | ppm |10 15 © 020 1.5 90530 1.5 92140 15 93850 1.5 95560 1.5 972

Tonnes Fish | Cubic M Peroxide | ppm10 2.5 148320 2.5 150930 2.5 153540 2.5 156350 2.5 159160 2.5 1620

| Tonnes Fish | Cubic M Peroxide | ppm |40 10 98380 10 994120 10 1006160 10 1017200 10 1029240 10 1042280 10 1054

Tonnes fish | Cubic M Peroxide | ppm40 15 147580 15 1491120 15 1509160 15 1526200 15 1544240 15 1563280 15 1581

14.06.2013 09:31:23 Page 3 of 6This document is not approved in a printed version. Approved version osrly exists electronically.

ID: 30553 Version no.: 002

Hydrogen Peroxide Treatment inTarpaulin Marine Harvest IrelandResponsible organization: I re la n d / M a r in e P rod uction / Fish H e a lthDocum ent category: P rocedures Last changed: 0 8 .1 0 .2 0 1 2 { M cM anus, C a th e rin e )Latest audit: N o t s e t N ext audit: N o t s e tA p p r o v e d :____________ APPROVED 0 8 .1 0 .2 0 1 2 ( M cM a n u s , C a th e rin e )_____________________________

10. Safety Risk Assessment & Process Flow:

MARINE HARVEST IRELAND Revision Date: 23/7/12

Hydrogen Peroxide Treatment_________ FLOW DESIGN_________A212 Move boat into position_______

A213 Lift net near surface of water |

A214 PutTarpaulin in position \

A215 Attach pipes to manifold_______| -------->|A221 Attach pipes to pumps

*I

A216 Place H2 O2 pipes in pen & attach

A217 Place oxygen pipes in penI

|A218 Dilute H2 O2 with water if required |

>A219 Pump Hydrogen peroxide to pen|

\A220 Rinse out system with water

24.06.2013 C§:31:13 Page 5 of 6This document is -rot approved in a printed version. Approved verson only exists electronically.

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H ydrogen Peroxide Lice Treatm ent in m Em . . ,, . _ , .wel I boats M arin e H a rv e s t Ire la n dResponsible o rg an iza tio n : I r e la n d / M a r in e P ro d u c tio n / F ish H e a lthD ocum ent catego ry: P ro c e d u re s Last changed: 0 3 .1 1 .2 0 1 0 ( M c M a n u s , C a th e n n e )Latest a ud it: N o t s e t N ext a ud it: 1 4 .0 7 .2 0 1 1A p p r o v e d : A P P R O V E D 0 3 .1 1 .2 0 1 0 ( M c M a n u s , C a th e n n e )

1. Scope

The following SOP describes the steps required to administer a Hydrogen Peroxide bath in a well boat for the removal of sea lice from fish.

2. Precautions:

2 1 Do not treat if the seawater temperature is greater than 12°C.

2.2 Do not bath stressed or unhealthy fish. This must be verified in advance of proposed treatment by veterinary inspection.

2 3 Ensure nets are clean before embarking on a treatment. Presence of net fouling in the vicinity of the treatment area will reduce treatment efficacy.

2 4 Do not treat immediately after heavy rain or storms as organic matter in land runoff will also impair treatment efficacy.

2 5 MSDS sheets must be up to date and available on site and in the well boat

3. Hydrogen Peroxide Treatment Concentration:

The recommended hydrogen peroxide dose is 1500ppm. To calculate use the following formula;

Well volume x 0.0015 x (100/ H2Q2 concentration)

Thus if the H2 Q2 stock concentration = 35% active by weight and the well volume is 700 cubic meters then;

700 x 0.0015 x (100/35) - 3 cubic meters of H;0- is required.

4. Equipment/staff:

4.1 IBC’s must be fitted with steel lifting frame which has four lifting eyes. Arrange tBC's on deck before moving fish

4 2 Plastic piping to fit hydrogen peroxide IBC "male” connection. Use quick fit connections supplied by the chemical supplier.

4.3 A minimum of 4 staff is required to carry out operations on deck.

4.4 All staff must have full PPE to include boots, PVC overalls, PVC gloves and full face mask.

14.05.2013 C9:3G:28 Page 1 of 3This document is arot approved in a printed version. Approved verson orriy ex sts e‘:ectrtrite ly.

ID : 2 3 3 9 2 V e rs io n n o .: 0 0 2

Hydrogen Peroxide Lice Treatment in Wellboats Marine Harvest IrelandR esponsib le o rg a n iza tio n : I r e la n d / M a r in e P ro d u c tio n / F ish H e a lthD ocum en t c a teg o ry : Procedures Last changed: 03 .11.2010 ( McManus, Catherine )La test a u d it: Not set N e x t a u d it: 14.07.2011A p p r o v e d - ._____________APPP.QVCD 0 3 . 1 1 .2 0 1 0 ( M c M a n u s , C a th e r in e )_______________________________

5. Loading fish:

5.1 Starve fish for a minimum of 50 degree days

5 2 Use a sweep net or a float line to crowd fish close to the side of the cage to which the wellboat is tied When using a sweep net, lift a full cage net to a depth which allows crowding offish without obvious signs of stress. Lower the sweep net into the water on the opposite side of the cage to the pump/siphon. Haul the sweep net slowly across the cage, gently crowding fish Secure sweep net to cage rail and reduce volume to a safe working load.Use a float line only when the sweep net is no longer viable or when there are less than 4,000 fish in a cage. Introduce the float line on the outside of the net until it surrounds the net at water level. Gradually pull the line towards the pump/siphon, allowing excess net to fall back over the float line. The fish are finally crowded into a narrow but deep pocket, avoiding entanglement in the net.

5 3 Pump or siphon fish into the well in accordance with the Skippers instructions Density should not exceed 100 Kg/m^. In any event the well boat Skipper will dictate a safe fish density.

5 4 Allow fish to settle down in the circulating well water for at least 15 minutes before commencing treatment. Monitor dissolved oxygen and supplement if necessary.

6. Attaching Equipment:

6 1 Ensure seawater in the well is circulating. Do not oxygenate.

6.2 Attach plastic piping with quick fit attachment to the number of IBC's required. Hang pipes into the well at mid and bottom depths.

6.3 Open top lids and valves on IBC's. Allow HjO- to flow into well This will take approximately 6 to 7 minutes to complete.

7. Treatment Duration

7 1 Fish are held in the treatment solution for 12 to 15 minutes after all Hydrogen peroxidehas been discharged into the well

7 2 Immediately thereafter, the skipper will open up all valves and flush the well with fresh seawater for approximately 15 minutes

7.3 Treated fish may then be pumped from the well to the pen with a pressurised system

8. Records:

14.06.2013 ©9:30:18 Page 2 of 3This document is not approved in a printed version. Approved version only ex sts electronically.

ID : 23392 Version no.: 002Hydrogen Peroxide Lice Treatment in Wellboats N p Marine Harvest IrelandR esponsib le o rg a n iza tio n : Ireland / Marine Production / Fish HealthD ocum en t c a teg o ry : Procedures Last changed : 03 .11 .2010 ( McManus, Catherine )La test a u d it: Not set N e x t a u d it: 14.07.2011A pproved: APPROVED 03 .11 .2010 ( McManus, Catherine )

Record all treatments on the attached treatment record It is the responsibility of the Site Manager to ensure all records are completed and signed. All records must be forwarded to the Marine Operations Manager and the Technical Manager.

9. Safety Risk Assessment: OPERATING CONDITIONS: Normal

Loading Hydrogen Peroxide Into Boat Staff Required for Task: 2

Risk Key: 1 - 3 = Low Risk4 = Medium Risk6 - 9 = High Risk

Hazard AdverseEffects

Hazard Score - NoControls

ControlsMeasures

HazardScorewithControl

Additional Controls Required

ChemicalSplash

Bum 9 PPE 3 No Control Req'd

FallingContainer

Crush 8 Chains 3 No Control Req’d

FallOverboard

Drowning 8 Lifejacket/Ring 3 No Control Req'd

Weather FallingGoods

8 Do Not Lift in the Wind

3 No Control Req'd

Forklift Crush 8 Training 3 No Control Req’dContainer Crush 8 Lifting Eyes on

IBC steel frame & Chain

6 Only use IBC with steel lifting frame.Review supply of H20 2 in bulk loads (25 cubic meters) directly to well boats.

24.06.2013 09:30:28 Page 3 of 3This document is mot approved in a printed version. Approved version orcJy exists eectronically.

Marine HarvestIreland

ID; 22961 Version no .: 001Sea Lice Treatment Rotation

R e s p o n s ib le o r g a n iz a t io n : Ire la n d / M anne Production / Fish H ealthD o c u m e n t c a te g o ry : Procedures L a s t c h a n g e d : 0 4 .1 2 .2 0 0 9 ( M cM anus, C atherine )L a te s t a u d it : N ot set N e x t a u d it : Not setA p p ro v e d : APPROVED 0 4 .1 2 .2 0 0 9 { M cM anus, C atherine )

Sea Lice Treatm ent Rotation:

1. Purpose:

To reduce the nsk of resistance development by sea lice to lice pharmaceuticals.

2. Responsibility:

MH Business Unit Vetennarians, Health Managers

• To ensure the procedure is implemented• To ensure the procedure is followed, in accordance with local requirements

To inform the Marine Harvest VP Fish Health & Welfare of any deviation from theprocedure and any changes in legislation, instructions or status of approvedmedicines that could influence this procedure

3. Procedure:

3 1 Where legislation and product availability permits, sea lice treatments will berotated to reduce selection pressure and resistance development

3.2 Where there is more than one chemical class available, there will be no more than 2 consecutive treatments with the same chemical class or product on the same site

3.3 Following 2 consecutive treatments with the same chemical class/product then an alternative chemical class/product will be used on the same site, even with a break of several months (due to fallowing and/or a new generation being stocked)

3.4 Treatments with products having shewn resistance will not resume until sensitivity is restored

3.5 Resistance b oassays will be conducted;

• If there are indications of reduced sensitivity to a particular product after any single treatment

• If more than 2 consecutive treatments are planned• If resistance to another product-chemical class exists• To document restoration of sensitivity

3.6 Product rotation should be applied as a zone management, targeting coordinated rotation also w thin neighbouring sites in the same area-' zone.

3.7 If product availability is limited and restnets product rotation as defined above, the BU must assure that necessary actions are taken to allow the

L4.06.2-.C13 L2 : 3 1 LL Page 1 o f 2Trris doc lament is net approved n a printed version. Approved version only exists electronically*

ID: 22961 Version no.: 001Sea Lice Treatment Rotation Marine Harvest

IrelandR e s p o n s ib le o r g a n iz a t io n : Ire la n d / M a rn e Production / Fish H ealthD o c u m e n t c a te g o ry : Procedures L a s t c h a n g e d : 0 4 .1 2 .2 0 0 9 ( M cM anus, C atherine )L a te s t a u d it : N ot set N e x t a u d it : Not setA p p ro v e d : APPROVED 0 4 .1 2 .2 0 0 9 { M cM anus, C atherine )

introduction/ approval of alternative sea lice pharmaceuticals (the actions can be specific MH actions coordinated through Group Technical Department/ VP Fish Health & Welfare or industry initiatives).

4. Additional Information:

Our experience shows that reliance on a single (or few) product (s) or technique will inevitably lead to the development of resistance to that product. The over-reliance on Slice, with its long sub-therapeutic residue profile, has caused particular problems. In addition, it is well known that treatments are never 100% effective and a proportion of tolerant lice exist which act as a reservoir for resistance development. The rotation of products, chemistries and modes of action is a well documented and successful practice in terrestrial pest management for mitigation of resistance development Product rotation means switching between products with different modes of action.

1 4 .0 6 .2 0 1 3 1 2 : 3 1 : 1 1 Paffe 2 o f 2T h is fioiTi. msnfa is -nob a p p ro v e d in a pcinbed v & rs io a . A p p co y a d v a rs io n o n ly e .K fcs d s d io n s a l l , .

ID: 25450 Version no.: 002

Lice Monitoring Marine Harvest IrelandResponsible organization: I re la n d / M a rin e P rod uction / Fish H e a lthDocum ent category: P rocedures Last changed: 1 4 .0 6 .2 0 1 3 ( S inead D o h e rty )Latest audit: 1 4 .0 6 .2 0 1 3 N ext audit: 0 2 .0 6 .2 0 1 4Approved: APPRO VED 1 4 .0 6 .2 0 1 3 ( M cM a n u s , C a th e rin e )

Risk Key: 1 -3 Low Risk4 Medium Risk6 - 9 = High Risk

Hazard AdverseEffects

Hazard Score - No Controls

ControlMeasures

Hazard Score with Control

Additional Controls Required

Slip/Trip/Fall Cuts/Bruisrg 8 Rails 3 No Controls Required

Fall Overboard Drowning 9 Lifejacket/Ring 3 No Controls Required

Cuts to Limbs 6 PPE 3 No Controls Required

Manual Handling Back Injury 6 Training 3 No Controls Required

Eye Splash Eye Injur/ 6 PPE 3 No Controls Required

14.06.2013 12:27:35 Page 2 of 2This document is ri»ot approved in a printed version. Approved versen only exists electronically.

OKeeffe, Therese

From: Kelly, JohnASent: 19 November 2012 16:42To: Quinlan, JohnCc: Corcoran, Pat; OKeeffe, ThereseSubject: FW: Aqualine Shot head drawingsAttachments: Drawing #1 .jpg; Drawing #2.jpg

Guys

FYI.

JAK.

From: OSullivan, Tony Sent: 19 November 2012 16:10 To: Kelly, JohnA Cc: McHale, JohnSubject: FW: Aqualine Shot head drawings.

John,Please see attached.I can confirm that the maps anddrawings submitted in support of the Shot Head application, including those submitted previously by MHI / { M M f ta r e now sufficient to support this application.I can further confirm that I have no objection to issue of the licence.Regards,Tony

Mr J McHale, ACE, Mr J.A Kelly, AFMD

14 May 2012

T5/555Aquaculture Licence Application T5/555 (as amended - Appl. date 20 June 2011). Applicant: Bradan Fanad Teoranta t/s Marine Harvest Ireland Site: Shot Head, Bantry Bay AQ Type: Marine Finfish - Salmon

I have reviewed the submission provided by Watermark, dated 03 April 2012, in response to my report of 27 January 2012.

A copy of the Admiralty Chart extract is attached again. This was attached to my report of 27 January 2012, but I understand that MHI did not receive it with the copy of the report (introductory notes on p1 of Watermark’s letter refer).

Comments on RPS Wave Climate Report Dec 2009

Watermark’s response in relation to Comments on RPS Wave Climate Report Dec 2009 includes additional expert views by RPS Consulting Engineers on hydrodynamic effects. These views generally provide assurance in respect of diffraction effects and depth at which waves will break (about 10m).

An item that requires clarification here is that RPS observe: “I cannot see M H I putting cages in under 10 m on this site so it seem s logical that the cages will be to seaw ard o f the change in depth.”However, it is noted that Watermark favour locating the cages to the northwest comer of the site (this is referred to on p80, Sec 2.4.6 of the EIS and is repeated again on p3 of Watermark’s current response). The northwest corner of the site is the shallowest part of the site, tending (at the very least) towards the 10 m contour (see Admiralty Chart). It would be important that the cages are not located within the breaking wave zone. As it stands, this could potentially happen, as it must be borne in mind that, in the context of the scale represented on the Admiralty Chart, the plan accuracy of depths cannot be guaranteed. It is understood that the cage depth will be 15 m in the middle, and obviously therefore, the mid­point of the net could not be located in such shallow waters, but parts of the net, and certainly, for example, the collar and possibly the anchors, could quite easily be located in too shallow a depth (it is acknowledged that there are limitations in that the anchoring system must remain within the site - however this depends on the in-situ arrangement of the anchoring system). While it is clear that it would be in the interest of the operators not to endanger the structure, nevertheless this does appear to be a risk that should be addressed by the applicant, as it is likely that the tendency will be to seek the most sheltered positioning, especially in cases of storm forecasts. A suggested means of resolving this issue is that the drawing to be provided (see below) could show a suitable “minimum” clearance from the northern boundary to the relevant part of the structure (the collar / sinker tube I assume).

Drawings to be Provided

The remainder of the Watermark report is adequate, except that we need to insist that the drawing(s) be provided, as requested. The drawing is required as it provides a basis for licensing the development: the licence template provides that the drawing is incorporated in a schedule to the licence. It is accepted that the drawing cannot be fully representative of the site bathymetry, the exact deployment details, etc., and it is also acknowledged that the cage positioning can change within the site, when operational.

It is suggested that a plan of the site and two cross-sections be provided (through the centres of the opposite facing site boundary lines - and show ing the elevaron or section through the structure). Bathymetric detail can be provided from information currently available. M H W S and M LW S should be show n relative to the se a b e d . Typical ropes arid anchor s y s te m s w a y

be shown, and the drawing can note, where applicable, that element details, sizes, etc. are indicative, but subject to detailed design requirements. The drawing should include details, to a larger scale, of smaller elements (ropes, shackles, etc). It would be useful to include a map or chart extract showing the site and site co-ordinates (possibly both to ING and ITM.

To assist in this, good typical detail is provided in the EIS: Fig 63, p153; Fig 64, p154 (photographs); Fig 72, p168 and consideration may be given to incorporation of these into the drawing. My report of 27 January 2012 sets out the requirements.

In the case of this application, the licence may be granted using new licence templates. This will require the drawings referred to above to be attached as a schedule to the licence. The drawings do not necessarily need to include exact dimensions of elements which are subject to detailed design and may be unknown at this stage, but to be an adequate representation of the development to be licensed. This process (submission of drawing for the schedule to the licence) may be compared to a planning application for a land-based development that has not as yet been subject to detailed design stage. The detailed design stage will involve a process to be completed post-issue of the licence. A condition of the licence, if/when granted, will require that the structure is certified be adequately designed.

The above process is considered necessary, as the licence will specifically reference the drawing(s) in a schedule. An EIS document accompanying an application, on the other hand, may present a wide variety of options, some of which may be acceptable and some not. Therefore, in order to licence a proposal that is generally acceptable, drawings showing the general layout to sufficient detail need to be referenced in the licence.

Certification Methodology and Timing

The five stage process proposed by Watermark is noted. I would comment at this stage that the future procedure to be used in the certification process is presently under consideration by the Department.

In the case of this application, essentially by virtue of carrying out the EIS, which is mandatory, the applicant will have all the fundamental design information in relation to wind, waves, currents, depths and generally sea bed to carry out the preliminary design. On foot of this the applicant will be in a position to do the preliminary design and sizing of components and thus be able to produce the drawings (Plans and Sections) to sufficient detail to be included in the proposed schedules and satisfy the licensing requirement.

It is fully accepted that the detailed design and final sizing and dimensioning (particularly specific components) will come later in the process. In the case of this application the drawing referred to above is required to facilitate the issue of the licence. Following issue of the licence full specification drawings will be required. A process similar to points 2 to 5 of Watermark’s letter could be acceptable in this regard, in the final analysis. Engineering Division must be satisfied that the structure is properly designed and certified to be so by a competent person.

Tony O'SullivanRegional Engineer (South Region)

4 )

•/?

39

1• O. w 0,000

Mr J McHale,ACE,

Mr J A Kelly AFMD

10 April 2012

T5/555Aquaculture Licence Application T5/555 (as amended - Appl. date 20 June 2011). Applicant: Bradan Fanad Teoranta t/s Marine Harvest Ireland Site: Shot Head, Bantry Bay AQ Type: Marine Finfish - Salmon

MED Report on Statutory and Public Consultation Process

1.0 Introduction

Mr. J. A. Kelly’s requests for observations refer, dated 20 February 2012, 27 February 2012, 14 March 2012 and 22 March 2012 respectively on (i) submissions received following the public consultation process, (ii) submissions received following the statutory consultation process, (iii) MHI response to submissions received following the public consultation process and (iv) MHI response to submissions received following the statutory consultation process in connection with MHI aquaculture application for a Salmon Farm at Shot Head, Bantry Bay. Eng Div reports to AFMD dated 28 October 2011 and 27 January 2012 also refer.

Comments below are referenced to correspond with MHI responses, in the main, rather than individual submissions (i.e MHI letters dated 12 March 2012 and 16 March 2012 relating to public submissions and statutory submissions respectively).

2.0 MHI letter dated 12 March 2012

It is noted that pages 17 to19 of MHIs letter dated 12 March 2012 lists the submissions made in tabular format, including the general observations made in each submission, by subject, and the section number and page in the EIS document that references the subject matter.

It is noted that in respect of every subject listed, with only two exceptions, there is a corresponding reference to where the matter is dealt with in the EIS document. The exceptions are: (i) smell and (ii) independence of consultant. The issue of smell is addressed on p16 of the letter and the response, which seems reasonable, indicates that this is not a matter of significant environmental effect. The matter of independence of the consullant does not appear to have been addressed. It is noted, however, that much of the material presented in the EIS report is referenced and/or has been prepared by sub-consultants (Eg: RPS Consulting Engineers), who I would suggest would not be regarded as partisan.

I would comment that the EIS appears to me to be properly compiled and to fully address the significant issues of concern: this is clearly indicated by the fact that the issues raised in the submissions, both at public consultation and statutory consultation stages, are generally the subjects given substantial consideration in the EIS. (I do not consider the matter raised concerning minor errors in the EIS document to be of significance). However, as it remains the single item that has not been responded to, perhaps MHI might be asked to address the particular item of independence of the consultant, for completeness.

MHI’s letter addresses the submissions under the following headings:

1. Covering Letter FolE2. Public Participation3. Hydrography; currents and sediment transport and deposition4. Phytoplankton5. HabitatS'Benthic Survey

6. Food Safety7. Wild Salmonoids8. Visual Impact/tourism9. Other Fishery Interests10. Navigation11. Local Issues

It is my opinion that the list of headings broadly covers the significant issues raised, and that these have been addressed comprehensively and adequately in the EIS and are further addressed satisfactorily in the response letter.

3.0 MHI letter dated 16 March 2012

3.1 MHI’s letter of 16 March 2012 offers responses to statutory submissions received from six bodies:

Inland Fisheries Ireland Bantry Harbour Commissioners Commissioners of Irish Lights EPADepartment of Arts, Heritage and the Gaeltacht An Taisce

3.2 Issues Raised

The issues raised in the statutory process can be summarised as follows:

Impact on wild salmonoids (incl escapes, sea lice, viruses, treatment chemicals and disposal) NavigationArchaeological Impact Assessment Potential cumulative impacts

These subjects are covered in the EIS and are further addressed in MHI's letter. I have no further comment to make regarding them, except to re-iterate that, in my view, navigation safety is the most important issue of concern regarding this application, both from a safety and environmental perspective; and this is a matter best addressed by the MSO.

I would also advise that the matter of archaeological assessment should be addressed and agreed with DAHG, but would comment that, as no permanent structures are proposed (and in particular no foundation structures are proposed to be constructed on the seabed - apart from anchors being deployed), and no dredging is proposed, there is very limited physical disturbance of the seabed, this issue should be resolved without too much difficulty.

4.0 Further Items

My report of 12 January 2012 requests (i) further analysis of the local wave conditions pertaining at the site and implications for the proposed structures and (ii) drawings be provided. These are still outstanding.

Tony O’SullivanRegional Engineer (South Region)

27 January 2012

T5/555Aquaculture Licence Application T5/555 (as amended - Appl. date 20 June 2011). Applicant: Bradan Fanad Teoranta t/s Marine Harvest Ireland Site: Shot Head, Bantry Bay AQ Type: Marine Finfish - Salmon

Comments on Response by Watermark to Eng Div Report of 28 Oct 2012

Mr. J. A. Kelly’s request for observations, dated 23 November 2011, on the MHI aquaculture application for a Salmon Farm at Shot Head, Bantry Bay refers. MHI response, by e-mail dated 21 November 2011, to internal consultees initial observations (including Eng Div report to AFMD dated 28 October 2011 which was copied to MHI) further refers.

The following points are noted:

1. RPS Wave Climate Report Dec 2009 received, as requested.

2. RPS Settlement Study - Shot Head Bantry Bay, Sept 2011 received, as requested.

3. Drawings showing cross-section through the site and elevation of the proposed cages and anchoring systems in relation to the seabed have not been submitted to date.

4. MHI suggest that a hydrographic survey of the site should not be required.

5. MHI suggest that proposed use of physical modelling should not be necessary.

6. RPS Report “Detailed Assessment of Wave Climate at the fish farming sites off Clare Island, Clew Bay, West Coast, Ireland, Dec 2010” received following later discussions with MHI.

Comments on RPS Wave Climate Report Dec 2009

Of note, in section 5.1, the wave height prediction given for 1:50 year storm from 240° direction at the SW Corner of the site is given as 5.549 m, with a wave period of 15.92 seconds (this is also presented in the EIS document in Table 4, p81).

In the EIS report (p80), it is suggested that, should the licence be granted, it might be worth looking at locating the cages towards the NW corner of the site. Here, the significant wave height is given as 3.265 m with a 15.92 second period. This is considerably less severe than conditions predicted at the SW corner (5.549 m - as above), but there is a question over whether location of cages towards the NW corner is a realistic proposition (see below).

By comparison the centre of the site is showing 4.863 m significant wave height (15.82 second period), which in itself is a considerably large wave prediction, whereas the SE corner has wave height of 5.031 m (15.82 sec period).

Of further note however is that, by comparison, a licensed site at Clare Island has 1:50 year return period waves of in excess of 6 m (up to 6.3 m) - ref. RPS Report Detailed Assessment of Wave Climate at the fish farming sites off Clare Island, Clew Bay, West Coast, Ireland, Dec 2010 (IBE0491/AKB/Clew Bay). This report was forwarded to the Department by MHI on 09 Dec 2012, following interim discussions with MHI. MHI also address this in their response (Table 1 refers).

Overall, the Clew Bay conditions, as shown, are considerably more severe than those predicted at Shot Head, and given that the cages in Clew Bay have been in position for many years without, I understand, experiencing serious weather impacts, this suggests that the proposals for Shot Head may be acceptable, subject to satisfactory assurances being provided in response to request for further analysis, as detailed below.

It is noted that the report by RPS does not consider the implications of the wave predictions for structures proposed to be deployed - it merely presents the predicted wave climate. This may be because the exact cage design is not finalised as yet and therefore it may not be possible to comment on stresses imparted on individual elements. Nevertheless, a commentary by the report’s author on the likely impacts would be useful, as the general size and type of structure is known. In particular, comments on wave impacts due to the proximity of the site to the shoreline and in particular any likely impacts that might occur from the steep rise in seabed height through the site approaching the shore should be considered.

In regard to depths pertaining at the site an observation was included in my report of 28 October 2011 that approximately one quarter of the site lies between the 15m and 30 m depth contours. MHI’s dispute this in their response. For the record I attach an annotated copy of the Admiralty Chart extract that was prepared by this Division to accompany the formal licence documentation. This clearly shows the 20m and 30 m depth contours running through the site. The chart further shows depths of 36 m and 38 m within the site area. Also, immediately adjacent to the shoreward side of the site depths reduce to below 10m.

The observation in relation to this is that there is a considerable rise in the level of the seabed locally through the site and directly adjacent to the site (a rise of well in excess of 20 m), and the wave climate implications, if any, of this steep rise should be considered and commented upon by the wave modelling expert, as stated above. The RPS model uses bathymetry data obtained from digital charts of the area supplied by C-map of Norway, but it is not clear from the report that these very local conditions are covered in the model (e.g. the very local steep rise referred to above). Additionally, any potential shoaling effects and diffraction due to proximity of Shot Head should be considered and commented upon. The advice of the modelling expert may inform the requirement for a detailed localised hydrographic survey to be undertaken (although I would comment that having further examined the Marine Institute INFOMAR data available for this area in the interim since my previous report I would suggest that sufficient hydrographic information is readily available to allow the proposed analysis to be completed - Item 4 above refers).

In respect of item 5 above, I agree, upon review, that physical modelling should not be necessary in this case, as MHI have demonstrated adequacy of (less robust - as stated) structures deployed over a long period in similar to more severe conditions in Clew Bay in particular. MHI should supply details of the computational stress test modelling, stress diagrams, etc. for individual components as referred to in their response (Section 6.0 - p5) when this has been completed, in due course (this does not have implications for the decision on licensing at this stage).

In relation to item 3 above, the drawings should be provided, as requested. This is/will be a standard requirement for all aquaculture licence applications, and although the information that will be contained in the drawing may be provided or inferred from other sections of the documentation (EIS in particular), the standard drawing gives a worthwhile representation of the proposed installation in context with the particular site and the seabed. It is noted that the Department has not yet made available guidance on typical drawings for finfish applications, but it is intended that this will be prepared in the near future. These drawings are particularly required as they will be referenced in the licence. In this particular case the drawing shown on Figure 63 (p153) of the EIS gives good information on the plan layout of cages. Figure 72 similarly gives a good plan layout in relation to the site and the shore. These show the plan detail sufficiently and could be incorporated in a drawing. Elevation and cross-section detail is less clear: Figure 64 demonstrates the underwater structures well, but does not show the anchoring arrangements and does not show the structures relative to the specific seabed profile pertaining to the site. HWM and seabed levels should be accurately representative of the site.

In summary, a typical drawing will be of A0 or A1 size, showing the site location in map format (to scales appropriate to the development showing the location regionally and locally - say 1:50,000, 1:10,000 and 1:10G0); site location in Admiralty-Chart format; a plan of the site, to appropriate scale, showing cage layout, anchoring arrangements, positions of aids to

navigation, etc.; an elevation (to scale) which will include the MHWS, MLWS and seabed profile to accurate levels, cage and net details, depth of nets below cage, depth below nets to seabed; cross-sections through the site showing cage details, proposed mooring/anchoring details, MHWS, MLWS, seabed profiles; Additional detail (eg: chain, shackles, aids to navigation proposed for the development) and notes should also be included.

In summary, the outstanding requests are (i) further analysis / commentary to be provided on the local wave conditions pertaining at the site and implications for the proposed structure as detailed above, and (ii) a drawing or drawings suitable to accompany the licence, as detailed above.

Tony O'SullivanRegional Engineer (South Region)

A q u a C u ltu re S i t e s1:3G,000

Denotes application

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28 October 2011

T5/555Aquaculture Licence Application T5/555 (as amended - Appl. date 20 June 2011).Applicant: Bradan Fanad Teoranta t/s Marine Harvest Ireland Site: Shot Head, Bantry Bay AQ Type: Marine Finfish - Salmon

1.0 Introduction

AFMD request for observations on the above application, dated 11 August 2011 refer.

The application date is 20 June 2011. The application is accompanied by an EIS in three volumes, dated May 2011. Volume 1 is the main document and references below are to this document. Volume 2 contains technical appendices and Volume 3 is a video of benthic dive surveys.

2.1 ProductionThe application is for a bi-annual production of 3,500 tonnes of farmed salmon. The production cycle is 24 months, with harvesting over 6 months between months 17 and 22 inclusive. The final 2 months are a fallowing period, prior to re-stocking. The peak standing biomass is 2,800 tonnes, occurring in Month 17/18 (c.f EIS p143, 144).

It is noted that the applicant is committed to high welfare organic salmon farming, which is welcome.

The proposed initial production strategy is for alternate stocking with the Roancarraig site further west in Bantry Bay. This would entail stocking of Shot Head in Year 1 and Stocking Roancarraig in year 2, resulting in harvest (and peak biomass) at each site separated by a 12 month period.

An optional future production strategy, synchronous stocking (with the Roancarraig site), is referred to in the EIS (p149). The benefits of a strategy such as this are outlined, including health management, etc.

AFMD should note that strategies as outlined, that link the production cycle to the production cycle of another farm, will have licensing requirements that pertain to two individual licences. This requires further examination with MHI, but is not a matter that particularly needs to be resolved prior to licensing of this application, I would suggest.

3.0 The Site - Navigation SafetyThe Site location is at Shot Head, Bantry Bay, close to the north shore of the bay between Ardigole and Glengarriffe. The site measures 850 m X 500 m, an area of 42.5 Ha. Apart from about three dwellings close by, the site is

generally remote from land dwellings and views. The principal features within the area are a quarry owned by Tarmac Fleming at Leahill and the Whiddy Oil terminal operated by Conoco Phillips. The quarry includes a pier from which stone is transported by sea. The Whiddy Oil terminal is relevant from a navigation perspective. Both of the foregoing have been cited as concerns at EIS Scoping stage, and generally navigation safety appears to be a particular issue of concern. Bantry Bay Pilotage have expressed concern in this regard, stating that vessels of c.96,0001 and 250 m length naviagate to Leahill Pier (confirmed in the EIS).

From Admiralty Charts the depths of water at the site range from (i) in excess of 30 m over most of the site to (ii) between 15 m and 30 m over about one quarter of the site to (iii) less than 15 m over a smaller portion of the site closest to the shore. This is at variance with depths stated in Par 2.3.1 (p51)

3.1 Floating Facilities

It is proposed to site 12 No. circular cage rings of dia. 41 m each (p153). These will be in a pattern of 2 X 6. Each of the 12 cages will be moored within a 70 m X 70 m grid square. The total area covered including moorings will be 420 m x 140 m (58,800 m2). Note that the site is 850 m x 500 m, giving room for re-positioning of the cages as may be required.

3.2 Mooring Blocks

The lateral mooring blocks (on the 6 x 2 grid) will generally be 1.37 m x 1.37 m in plan dimensions, weighing 1000 Kg each, and the axial moorings will be 1,500 Kg each. Detailed drawings of the blocks are not provided.

3.3 General comment on Farm layout / Design

While generic drawings of the farm layout are included in the EIS document (Vol 1, p 153), and text details of the layout and mooring arrangements are supplied (p155), drawings showing cross-sections / elevations in particular are not supplied with the licence application.

Cross-sectional drawings, to scale, through the entire site showing the cages and anchoring arrangements in relation to seabed levels and showing, in larger scale, details of the anchors and mooring arrangements are not provided. It is noted (par 3.3.2, p152) that the EIS does not purport to supply the detailed information required in this respect, however this should be supplied prior to issue of a licence (i.e at the application stage).

A generic design appears to have been developed for MHI salmon farms, as detailed in the EIS, but details of the design assumptions and criteria used are not supplied.

4.0 Bathymetry / Hydrography

It is noted that the depth to the mid centre of the bottom net is 15 m.

Bathymetric surveys are supplied with the EIS. However, a detailed hydrographic survey of the site has not been supplied. From information supplied (from Admiralty Chart on p 55), it is noted that the seabed levels vary considerably over the site area, with available water depths ranging from in excess of 30 m at the seaward sides to between 15 m and 30 m over a portion of the site and to less than 15 m in parts towards the shore side.These depths are at variance with information given in Section 2.3.1., where it is suggested deeper depths are available throughout the site. It is also noted that the information given in 2.3.1 appears to rely on Figure 19 which is an INFOMAR bathymetric survey of the entire bay. It is unlikely that the scales and accuracy of detail used here would give sufficient detail of the site.

Further, it is also noted that a rock anomaly (100 m x 40 m) has been identified in the middle of the site which it is stated could have implications for shooting of moorings. On-site measurements (during diving survey) indicate that the rock protrusion may raise the seabed level by about 4 m in the centre of the site.

In the circumstances, and particularly because this site is located very close to the shore, it is recommended that a detailed hydrographic survey of the site be carried out to a grid or run spacing of about 20 m. A copy should be sent in hard copy and electronically to the Department.

5.0 Dispersion and Deposition Modelling

Dispersion and sediment transport modelling was conducted by RPS Consulting Engineers, using MIKE 21 and MIKE 321 NPA software developed by DHI. The input data was taken from current meter results (deployed at the site at various depths over two separate tidal cycles - during which notably wind conditions were atypical), proposed input feeding rates, feed conversion rates (solids both waste feed and faeces considered), tidal and hydrodynamic modelling of Bantry Bay and INFOMAR Bathymetric data.

Current speeds in the bay are slow, typically below 15 cm per sec. At the seabed lesser values can be expected. The ebb tide is shown to be slightly greater than the flood tide. I would comment that the effect on dispersion is likely to be lessened by the effect of prevailing wind induced currents for much of the time.

The Report examines combined discharges from the two MHI sites (Shot Head and Roancarraig) which it is proposed will be stocked on an alternate production basis over a two year cycle. The annual discharges are given as 1,100 tonnes BOD (combined site peak of 123.17 tonnes in January), 775 tonnes faecal and food waste, 157 tonnes total N, 23 tonnes total P. As stated this is based on alternate stocking, but this would change if synchronous stocking is proposed.

The conclusions given in the report of the dispersion and deposition analysis are that resuspension and dispersion away from the cage sites is unlikely under normal still weather conditions. From SEPA studies, critical resuspension speeds are 9.5 cm per sec and critical deposition speeds are 4.5 m per sec. I would comment that benthic impacts will be greatest underneath the cages as stated in the report, but allowance should be made for impacts further away from the cages than indicated in the EIS.

Section 4.7 of the EIS (p 201) uses a dilution box model encompassing all salmon sites in Bantry Bay and gives conclusions on flux values for dispersion and dilution of nutrients and solid wastes. The model relates farm output data sets for nitrogen and phosphorus against oxygen and tidal flux. The conclusion from this analysis is that substantial exchanges occur both into and out of the bay as a whole, suggesting that oxygen depletion and eutrpphication is not a significant issue for the proposed farm. I would comment that the findings should be treated with caution, as factors such as prolonged periods of settled weather, conditions such as high temperature and calm winds could have most significant effects. It is notable that the report states that “the greater the box area considered, the greater the calculated dilution and dispersion will be” (p207), albeit reasons are given for choosing the “notional” box area used in the study. I would suggest that the studies conducted, such as current metering, and computational modelling of the site are more reliable in this regard and values of 1,000 fold increase in dilution of soluble discharges at 120 m from the site, as indicated from these studies, are more acceptable for licensing purposes. I recommend that on-site monitoring of conditions against baseline data be used as criteria for determining any requirement for change of operational practices.

Carrrying capacity of the bay is mentioned briefly (p 201), but it is stated to be beyond the remit of the EIS document (presumably because this requires study of other sites and incorporation of their contributions to environmental effects).

6.0 Wave Modelling

Wave analysis is discussed in Section 2.4.4, p 76.

RPS Consulting Engineers conducted the hydrodynamic studies for the EIS and this has been incorporated into the Watermark EIS Report. A copy of the RPS report should be requested (see footnote 49 on p 209).

The 1:50 year return wave at the site is propagated from 240°, representing a severe Atlantic Storm from a SW direction. Wave heights of up to 4.8 m with wave period 16 seconds could potentially cause equipment stresses.

The report concludes that “overall the model predicts wave climate at medium to high intensity”

The potential impact of waves on the finfish structures is not discussed in any detail.

I would regard the report and conclusions as a matter of serious concern.Predicted wave conditions could potentially result in serious structural damage to the structures, the consequences of which could include fish escape and serious damages caused by floating debris. Even under annual storm events, wave predictions at the site of 3.30 m (12.8 sec periods) are of concern.

Neither the EIS nor the application documentation provide specifications, design detail, or certification for the final structures proposed for deployment at Shot Head, as it regards these to be “not a matter for this document” (3.2.2 p 152). However, I would regard this to be a serious disregard of the issues presented in the wave climate analysis.

It is suggested in the EIS that this matter will be dealt with by licensing conditions, and this may in fact be the case in respect of certification, etc. Nevertheless, I consider MHI should address the issues of wave climate and demonstrate site suitability in this regard at an early date and this should in my view be a matter pertinent to any decision to issue a licence.

I would suggest, given the severity of predicted wave conditions, that the proposed structure should be subject to physical wave modelling to assess the structural stability of proposed structures under simulated conditions.

7.0 Conclusions and Recommendations

7.1 From EIS scoping, the most highlighted risk is to navigation safety. I agree that this is of primary importance, given the proximity of Whiddy Oil Terminal, traffic to/from Leahill Quarry, other vessel traffic utilising Bantry Harbour and occasional Cruise Liner traffic. Observations from MSO will be of primary importance in this regard. The following clause should be included as a licence condition (already included in current draft licensing documentation):

“The Licensee shall ensure that the equipment (including nets, all flotation, mooring and anchoring devices) is placed within the licensed area only. Storage or placement of equipment or stock on the foreshore or seashore outside the licensed area is not permitted under any circumstances.”

7.2 It is recommended that a hydrographic survey of the site be carried out to a grid or run spacing of about 20 m. This should be submitted to the Department in both hard copy format and electronically.

7.3 A copy of RPS modelling study report should be requested (see footnote 49 on p 209 stating that this is available if required).

7.4 MHI should address the sustainability of structures proposed at Shot Head to withstand wave climate predictions given in RPS Report, and this should, in my view, be a matter pertinent to any decision to issue a licence (albeit this may be addressed under licensing conditions also).

I would suggest that, given the severity of predicted wave conditions, the proposed structure should be subject to both computational (computer aided) and physical wave modelling to assess structural stability under simulated conditions.

7.5 The following clause should be included as a licence condition (included in current draft licensing documentation):

“The Licensee shall confirm to the Department of Agriculture Food and the Marine (hereinafter referred to as “the Department”), by way of written confirmation by a Chartered Engineer that the integrated floating and mooring system used in the licensed site is fit for purpose and is capable of containing the farmed fish. Any proposed material change to the equipment being used during the licensing period will require written confirmation by a Chartered Engineer that the installation remains fit for purpose. The Licensee shall retain adequate detailed records for inspection to confirm that this condition is being complied with."

Tony O’Sullivan Engineer Gr 1

Aquaculture Licensing SectionAquaculture and Foreshore Management DivisionDepartment of Agriculture, Food and the MarineClogheenClonakiltv Co, Cork

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13* February 2012

Re: Aquaculture and Foreshore Licence Applications by Marine Harvest Ireland for a deep sea finfish farm in Bantrv Bay, County' Cork

Dear Sirs,

I refer to correspondence received by the Agency from Marine Harvest Ireland dated 11th January' 2012 in relation to the above applications.

If the activity is likely to have a significant impact on a European Site (i.c. SAC, SPA, candidate SAC or proposed SPA) then an Appropriate Assessment of the implications for the site in view of the site’s conservation objectives must be carried out. When it is considered that an Appropriate Assessment is not required, a reasoned response should be provided.

In addition, the activity should not result in a contravention of the Water Framework Directive 2000/60/EC, Marine Strategy Framework Directive 2008/56/EC, the Environmental Liabilities Directive 2004/35/EC. the Shellfish Directive 2006/11 3/EC, the Bathing Water Directive 73/160/EEC. the Dumping at Sea Acts 1996 to 2010 etc.

Yours sincerely.

Dr. Tara ! liggins

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Mr John A Kelly,

Aquaculture and Foreshore Management Division, Department of Agriculture, Fisheries and Food, Clogheen,Clonakilty,Co. Cork.

21s* February 2012

Letter of objection for Marine Harvests proposed Salmon Farm at Shot Head 2012

Dear Mr Kelly,

Bantry Bay Harbour Commissioners are the statutory body responsible for the control of all

shipping and other activities in Bantry Bay. The Harbour Commissioners are conscious of the

valuable contribution made by the aquaculture sector to the local economy and have been

supportive of such developments where they do not interfere with the commercial activities of

the p o rt. Bantry Bay extends ENE for about 20 miles with depths generally over 30 metres and

can accommodate the largest vessels trading in Europe.

The Bay has provided a safe haven for many large oil tankers and bulk carriers in the past

when they encountered difficulty at sea and required shelter to carry out repairs.

Oil tankers and cruise liners account for the majority of shipping movements in the Bay and

prior to its closure, stone was exported from Leahill Quarry on the north side of the bay in large

bulk carriers loading up to 70,000 tonnes of cargo at a draft of approximately 8 - 1 0 metres

O&C

SPM is licensed for and can accommodate Very l arge Crude Carnets (VLCC) which typically

have a draft of 21 metres fully laden A significant proportion of the national oil reserves are

also stored in the Oil Terminal.

The proposed development is to be located in deep water close to the point where pilots board

incoming vessels and also where large tankers anchor when a berth is not available. The

presence of the proposed salmon farm is an additional impediment to be taken into

consideration when manoeuvring the vessels. While the Bay is generally wide enough to cater

for the largest vessels, the development, which is to be located in deep water, will reduce the

available navigable width.

In the case of anchored vessels there is also potential for damage to either the development or

a vessel in the event of a vessel dragging its anchor in adverse weather conditions. While such

events are rare and a prudent ship master will remove his vessel from potential danger, it is

while manoeuvring the vessel in such circumstances that the presence of the development will

pose a hazard

In recent days environmental issues in the locality have been raised by groups and individuals,

Bantry bay Harbour Commissioners are not in a position to verify the issues raised in the timeif,

scale available. However, Commissioners envisage that you will give these issues due

consideration in your deliberations.

Bantry Bay Harbour Commissioners object to the proposed development on the grounds of its

location.

Yours sincerely,

MichaeiHeftnebfy- - Chairman

Aquaculture Licensing SectionAquaculture and foreshore Management DivisionDepartment o f Agriculture, Food and the MarineClogheenClonakiltyCounty Cot k

Shot Head Aqua

16/01/2012

C.C. Capt Neil Forde, M.S.O,

Re. Marine Harvest Ireland, Shot head, Bantry Bay, County Couk, Aquaculture ansforeshore license applications/

D e a r S ir /M a d a m ,

Please find below our comments/concerns regarding the proposals for an aquaculturedevelopment off Shot Head, Bantry Bay.

1) Bantry Bay is a busy shipping route with particular safety risks including oil tankers transiting to the Whiddy Island Terminal and Cruise Ships transiting to Garnish. The Bay itse lf is a relatively narrow navigation channel, which would be narrowed further by the addition of this proposed site.

2) The application includes proposals to include navigation lights on each of the 4 comer grid buoys. These lights should be yellow, have a 3nm range, and preferably die 4 corner grid buoys themselves should be yellow in coiour to help distinguish them from the other grid buoys.

3) Hie application includes details of 2 Navigation buoys at the SW and SE corners.The application states that these will be special mark buoys. Given the high risk nature of the passing traffic, we would recommend that South Cardinal otioys be installed. We recommend that buoys of a significant size (min 1.5m diameter) are utilised, with the appropriate day-marks and top-marks. The buoys should each include a while light displaying the appropriate south cardinal character with a 4nm range. these buoys should ideally be installed circa 100m south of the extreme SW and SE cage mooring points.

4) (he application includes a budget of £12,000 to provide navigation buoys, fights and radai reflectors th is figure may be insufficient given our recommendations

i"r,-. , la c

An TaiseeAquacuilure & Foreshore Management D ivisionDepartment o f Agriculture, Fisheries & FoodClogheenClonakiltyOo.Cork

RF: Aquaculture and Foreshore Licence application by Murine Harvest for Shot HeadBantry Bay site Application number - T5/555

Dear Sir / Madam

Whilst An Taisee supports Ihe sustainable development of atpiaculture, the granting o f

licenses must be in keeping with other objectives for the area, and developed in a balanced

manner which is not damaging to the site’ s eco logy and ecosystems. Considering the applicants'

assertion that they wish to pursue sustainable, environmentally responsible practices, An Taiscc

submits that the full adoption o f Single Bay Management / C L A M S protocols for all their

operations around Ireland, including Bantry Bay in necessary.

An Taisee would like to request that Marine Harvest’ s monitoring reports are made available to

the public, either by being published on the company and / or D A F F websites regularly and in a

timely fashion. The monitoring reports should include the outcomes from the Inspector's report

and an inspection regime should ensure regular assessments are carried out.

Potential cumulative effectsThe EIS did not contain sufficient information on the potential cumulative impacts arising from a

5lh salmon farm in the bay.

Sea louse control:In v iew o f the now well established fact that sea lice emanating from salmon farms exert

detrimental e ffects on w ild salmonids (Gargan et al 2012), we ask that the Monitoring Protocol

for Offshore Finfish Farms- Sea T ice Monitoring and Control as recommended by DAFF is

fo llowed . This entails annual synchronous fa llow in g o f production sites as opposed to

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alternate biennial fallow ing as proposed by the applicant. The development o f a Single Bay

Management/CLAMS protocol for Marine Harvest’ s operations around Ireland, including Bantry

Bay. may also convince other, smaller operators in the same locations, such as Fastnet Irish Ltd

in Bantry Bay to carry out and profit from more effective sea louse control programmes.

An Taisce note on the marine harvest website it is stated that an environmentally sound and

efficient alternative to traditional delousing agents has been established. Intensive testing o f a

new delousing agent shows that peroxide is more than 90 percent e ffective on mobile and mature

lice. However, there is evidence to suggest that this treatment on ly removes the lice from the

salmon without necessarily killing them. Thus, the parasites can return to the cages, or worse,

infest w ild salmon. In Norway, hydrogen peroxide has fallen into complete disuse (Treasurer and

Grant, 1997). Another study by Bravo el a l (2010) indicates that quickly (20-30mins) after

hydrogen perioxide treatment most o f the parasites recovered from the treatment and were

available to infest new hosts. Thus, there is extremely conflicting evidence and An Taisce

submits there is still significant threat to w ild fisheries from lice infestations.

The results from the inspections by officers o f the Marine Institute

Sourcing of organic, IPN-free smolts:W here is the source o f organic smolts in Ireland?

During 2011, Marine Harvest sustained significant losses, as a result o f Infectious Pancreatic

Necrosis V im s in its Irish operations. This virus is highly resistant to treatment, and vaccine

effic iency is uncertain. Even more w orryingly infected farm escapees are a thought to serve as a

significant source o f infection for w ild salmonids (Ruane et al 2007). Would be applicant please

clearly state where they plan to source uninfected smoit for the new operation and how they

propose to control future outbreaks.

Disposal of Sea louse control baths:H ow are sea louse control baths, some o f which contain h ighly toxic substances (e.g.

Dcitainethrin and Cypermethrin the active ingredients o f Aiphamax and Excis respectively, are

highly toxic to fish, crabs and lobsters. Marine Institute 2006), to be disposed o f after use?

Yours Sincerely

Camilla KeaneNaiuia) Environment OfficeAn Taisce

An TaisceT h i ' \ i i i i f i i ' l h f f U w h '^ U n u t

ReferencesP.G. Gargan, G. Forde. N . Hazon, D.J.F. Russell, and C.D. Todd, 2012. Evidence for sea lice- induced marine mortality o f Atlantic salmon (Salm o salar) in western Ireland from experimental releases o f ranched smolts treated with emamectin benzoate. Can. J. Fish. Aquat. Sci. 69: 1 -11

Marine Institute, 2006. Dangerous Substance Usage in Finfish Aquaculture,Report prepared by the Marine Institute for SW RBD , Marine Institute Oranmore, Co. Galway

Ruane. N ., Geoghegan. F., O ’ Cinneide, M. 2007. Infectious pancreatic necrosis virus and its impact on the Irish salmon aquaculture and w ild fish sectors. Marine Environment & Health Series, No. 30. Marine Institute Oranmore. Co. Galway

James W . Treasurer • , Andrew Grant. Marine Harvest McConnell, Farms O ffice , Blur Mfcor Industrial Estate, Fort W illiam , PH33 PT, UK. Availab le online 25 March 1999.

I f t H i l l f f f !

Ealaion, Oidltreachta aijus Gaeltachta

Dt’/nu tw e n t ofArts, Heritage and the Gaeitacht

21/02/2012

Our ref. M00064/20IIYour ref. Application for Aquaculture Licence by Marine Harvest Ireland Ltd.Aquaculture and Foreshore Management Division,Department o f Agriculture Fisheries and Food,Cloghecn,Clonakilty,Cork.

RE: Aquaculture Licence Application by Marine Harvest Ireland L.td. to develop anoffshore fishfarm at Shot Head, Bantry, Co. Cork.A Char a,

I refer to your notification with respect to the above proposed development application and additional revised report, please find hereunder underwater archaeological observations and recommendations o f the Department o f Arts, Heritage and the Gaeitacht, for consideration by your Authority.

The submitted EIS does not address the underwater archaeological potential o f the area. Stated in section 6.6, page 33 is that this Department was consulted on the application at scoping stage and because there was no response forthcoming, it is to be assumed that there was no perceived requirement for an archaeological assessment. The area in question does have a high potential to retain underwater archaeological material in the form o f shipwreck archaeology or archaeological artefacts, which could be impacted by the proposed fish farm development, which is large in scale and which entails the use o f a large number o f seabed anchors. It is therefore required that a detailed underwater archaeological assessment be carried out in advance o f the foreshore licence permission being considered. This assessment should take the fo llow ing format:

A rchaeo log ica l Im pact Assessment

® The applicant shall engage the services of a suitably qualified undetwater archaeologist to carry out a detailed assessment of all proposed impacts to seabed. This shall include a desktop study that consults the Register of Monuments and Places, the Shipwreck Inventory of Ireland archive, both house with the Department o f \r's. Heritage and the Gaeitacht. and the Torographii'il riles of the National Museum of Ireland; other sources which shall be

• AH surveys shall be combined with a hand held metal detection survey.

• A ll surveys shall be licensed under the National Monuments Act 1930-2004 and the licence applications should be accompanied by a detailed method statement.

• Having completed the work, the archaeologist shall submit a written report to the Department o f Arts, Heritage and the Gaeltacht, in advance o f any decision being made on this application.

• Where archaeological material/features are shown to be present, preservation in situ, preservation by record (excavation) or archaeological monitoring may be required.

• Further archaeological mitigation may be required based on the results o f the underwater archaeological assessment results, including test excavation, structural recording, avoidance/change o f design, etc.

Reason : To ensure the continued preservation (either in situ or by record) o f places, caves, sites, features or other objects o f archaeological interest.

K indly forward any further information received or in the event o f a decision being made a copy o f same should be referred to the follow ing address:

The Manager,Development Applications Unit (DAU),Department of Arts, Heritage and the Gaeltacht,Newtown Road,WexfordAlternatively, documentation associated with the above can be referred electronically to the D A U at the fo llow ing address:

niaiianei.daufVt‘.ahg.gov ,ic

In addition, please acknowledge receipt o f these observations by return.

"please note the change la e-mail addresses, which take ejfcct from /2:00pm on XIomlay, I5fh August 20! I "

Is mists le meas,

/ ■ f'V w .

tvinmct Deegan,Developm ent Applications Un it T e l: (053) 911 7384

Aquaculture Licenceing Section.

Aquaculture and Foreshore Management Division.Department o f Agriculture Food and the Marine.C logheen.C lonakilty Co.Cork.

01 February 2012

Re: Marine Harvest Ireland, Shot I lead. Ban try Bay, Co. Cork.Aquaculture and Foreshore Licence Application.

A chara,

1 re fer to the above-mentioned application details o f which were received by (F I on 12th January 2012.

Th e current applications relate to a proposed salmon farm at Shot Head, Batury Bay with a total capacity o f 3500 tonnes. There are 5 principal salmonid rivers discharging in to Ban try Bay, these being M eelagh, Owvane, Adrignle, C oom holaand G lengarilT Rivers. AH 5 rivers are known as salmon and sea trout fisheries. Inland Fisheries Ireland ( IF I ) is the state agency responsible for the protection, management and conservation o f Ireland's inland fisheries. Th e proposed development has the potential to impact negatively on the aforementioned rivers and their salmonid stocks. It is in this context that IFI makes to fo llow ing comments on the proposed development.

As outlined in the HIS at present, there are currently lour licensed salmon farm sites in Bantry Bay. In total these sites are licenced to produce 2500 tonnes o f salmon per annum. 1 he current application i f -successful would result in a more that 100% increase in tanned salmon numbers in the Bay. !F1 considers that the current FIS is inadequate in that no serious assessment has been carried out ter (a) quantify die impact of the existing salmon farms in the hay on w ild migratory salmonids to date or (b) to quantify the tilt ure impact of the proposed dev elopm ent in its own right and in combination with other existing farms on wild migratory salmonids or (c i establish adequate baseline data for wild m igiuiorv salmonids in Bant;> Bay.

i he impacts referred to in (a j and (b) might relate to hot inn be confined « »

l. Se a U t v

Ercaptn and their interaction w ith wild populations and habitats.3. Spread of DHe-.w . and Parasite Curt sol4. Genetic Dilution

!F1 is concerned that an expansion o f the industry on the scale proposed in Bantry Bay w ill introduce conditions, which provide for an increasingly negative impact on w ild salmonid populations. In the absence o f information in this regard IFJ consider that the Precautionary Principle should be applied and that no further tonnage should be licenced in Bantry Bay and that an alternative site remote from salmonid rivers should be selected for the proposed development.

IF I would ask to be informed when further information is submitted and when a decision is reached on these applications.

Yours sincerely

Mtcnaet McParllandSenior Fisheries F,nvironmental O fficer.

Hayes, Liz

From:Sent:To:Subject:Attachments:

Rosaleen NiGhriallais - (DECLG) [Rosaleen.NiGhriallais@environ.ie] 22 August 2014 14:21 Hayes, LizAcquaculture report, T5/555SHOT AQUACULTURE SALMON FARM IN BANTRY BAY.DOC

Hi Liz,

Please find attached our observations on the acquaculture application, Shot Acquaculture salmon farm in Bantry Bay.

Regards,

Rosaleen Ni Ghriallais Marine Planning & Foreshore,Dept of Environment, Community & Local Government,Newtown Rd.,Wexford.Rosaleen. niehriallais@environ.ie

* * * * * * * s * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **************= !:*******Is faoi run agus chun usdide an te no an aonan ata luaite leis, a sheoltar an ri'omhphost seo agus aon comhad ala nasctha leis. Md bhfuair tu an ri’omhphost seo trf earraid, dean teagmhail le bhainisteoir an ehorais.Deimhnftear leis an bhfo-nota seo freisin go bhfuil an teachtaireacht rfomhphoist seo scuabtha le bogearrai frithvtorais chun vforais rtomhaire a aimsiii.This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager.This footnote also confirms that this email message has been swept by anti-virus software for the presence of computer viruses.

1

To Whom It May Concern,

RE Aquaculture Licence and accompanying foreshore licence application from Marine

Harvest Ireland for salmon farm development at Shot Head, Bantry Bay Co Cork-DAFM'S

communication to DOEHG-{your minute of 10/7/2014 to E Mooney also refers)

In relation to the above this Aquaculture Licence Application as made to DAFM has been referred to DOECLG (Foreshore Unit) for comment. Our views are as follows:

OVERVIEW

Marine Harvest Ireland is applying for a licence to farm Atlantic Salmon off the south coast of Ireland (off Shot Head in Bantry Bay). An EIS has been prepared and has been submitted to DAFM as part of the Aquaculture Licence Application .Watermark aqua environmental (Consultants acting on behalf of Marine Harvest lreland)have carried out extensive scientific and environmental investigations including studies of local geography, topography, hydrography, wave climate,water depth and visual impact on the locality and coastline and of candidate sites remaining in Bantry Bay it was submitted that the area selected to the east of Shot Head is the most suitable

PROPOSED DEVELOPMENT

The licence application is for a site that can accommodate the safe and efficient farming of 3500 Tonnes of salmon per annum-reaching this target in year 4- with intermittent fallow periods as outlined at Q2( viii)( a) in the completed Application Form .The area of the site as proposed (ref completed Aquaculture Licence Application Form and Drawings/Maps appended thereto) is 40HA(850m x 500m), however the actual footprint of the proposed cages within this area is much smaller at 5.88HA( 420m x 120m) as shown on the Drawing accompanying the application.

The fish will be held in circular net pens/cages with 12 No cages deployed for the first 15 months and temporarily rising to 14 No during biennial grading/harvesting for 4 months between Months 16-20(Feb-June in year 2 of cycle). Site will be fallow for up to two months between Months 23 and 24 before restocking

Cages will be circular plastic frame (128m circumference-40.8m diameter) comprising stanchions, rails and galvanised steel reinforced triple-pipe flotation collar. The cages will have a cubic capacity of 19000m3 per cage with a depth of 15m from mid centre of bottom net. The mooring and anchor arrangements are shown with reference to drawings accompanying the application. It is proposed to fit a yellow flashing light to each corner of the mooring system. Radar reflectors will also be fitted on all corner cages and on the centre cages. A navigation buoy with flashing light, yellow St Andrew's cross and radar reflector will also be moored to the SE and SW corner anchors. Proposed navigational aids may be modified, consistent with the specification requirements for the site as set down in the terms of the Aquaculture Licence, an/or as advised by MSO and CIL. A generalised layout and specification diagram for the proposed navigational aids/lighting/markings is provided with the application form.

No access across the tidal foreshore will be required by the company, however nearby piers(Castletown Harbour, Beal Lough Pier.Ardrigole Pier and Trafrask pier,and some subsidiary piers) will be required for the movement of vessels to and from the site as outlined at 2 I in the completed application form.

In their determination of this Aquaculture Licence Application DAFM can be advised to take cognisance of the following:

STRUCTURAL INTEGRITY

I t is noted th a t the site as proposed along the coast betw een Shot H ead an d M e h a l H ead is in an unsheltered an d reasonably exposed location in B antry Bay. The Applicants w ould need to dem onstra te to D AFM 's satisfaction the s tructural in teg rity o f the proposed anch or/m o oring arrangem ents fo r the cages especially in re la tion to extrem e w ave /cu rren t and tidal situations linked to extrem e w e ath er conditions. They w ould n eed to dem onstrate th a t the proposed structures are f i t fo r purpose un d er a ll these extrem e conditions. Cage and ro p e /n e t fa tig u e an d w e a r a n d te a r over tim e w ou ld also need to be fa c to re d into this assessment and the Applicants w ould n eed to satisfy D A FM in re la tion to th e ir contingency plans fo r dealing w ith defective or loose structures should they arise.

NAVIGATION

W hile a proposed navig ation m arking an d lighting system is p u t fo rw a rd in the application it is no ted th a t the "proposed navigational aids may be modified, consistent with the specification requirements for the site as set down in the terms of the Aquaculture Licence, as advised by MSO and CIL" this is acceptable

VISUAL AMENITY

This m ay be considered a scenic p a r t o f the Bantry B ay/W est Cork Coastline and the proposed structures, which w ill be w ithin app 300m o f the coastline a t the ir nearest point, m a y im pact visually on this status. It is recom m ended th a t the views o f Cork Co Co should be obta ined in this regard.

The Applicants w ould need to dem onstra te to the satisfaction o f Cork Co as appropria te th a t the proposed developm ent is in conform ance w ith the re levant County D evelopm ent Plans in term s o f its policies and plans in re la tion to visual and tourism am enity along the re levant coastlines an d in p articu lar the B antry Bay coastline adjacent to the proposed salm on fa rm .

This is without prejudice to any views that the NPWS (within DOEHLG) may have from a nature conservation perspective.

Regards,

Rosaleen Nf Ghriallais Marine Planning & ForeshoreDepartment of Environment, Community & Local Government, Newtown Rd.,Wexford.Rosaleen.nighriallais@environ.ie