Cruit Strand Co Donegal
An Italian businesswoman has asked permission to set up Aqua and Oyster farms on the amazingly beautiful strands of Cruit Island and Keadue, Donegal. This is in a special conservation area of enormous natural beauty and significance. It is a beautiful natural strand and a pristine environment.
You can object to the proposed desecration in two ways.
- By emailing objection letters to the project to the Minister of Aquaculture and Foreshore Management Division, Brendan Farr or his administration officer, Karen Gill by the 11th October (for Keadue Strand) and 15th October (for Cruit Strand) (Addresses below) You are free to edit the templates as you wish.
- By passing this information on to other parties you think might be interested.
- By signing the petition at: Save our Strands
They are small communities around there, so they need our help to add to the weight of signatures.
Templates for letters of objection can be found below. We suggest you copy these letters, (Case reference for Cruit Strand: T12/458 A&B and Keadue Strand Case reference: T12/474 A & B) and paste them into an email to either:
Karen.gill@agriculture.gov.ie or Brendan.farr@agriculture.gov.ie.
Please ensure that a letter for each Strand is sent to the Minister or Ms Gill. (See below)
TEMPLATE FOR CRUIT STRAND REF T12/458 A&B:
Aquaculture and Foreshore Management Division,
The Department of Agriculture,
Food and the Marine,
Clogheen,
Clonakilty,
Co. Cork
7 October 2016
Case reference: T12/458 A&B
A chara,
As part of the Irish Diaspora, I am writing to make a formal observation, pursuant to Regulation 9 of the Aquaculture (Licence Application) (Amendment) Regulations 2012, with respect to the Aquaculture licence application cited above. The applicant (Ms Benedetta Cazzamali, t/a Miss Oyster Ltd ) is seeking permission to carry out Marine-based and Mari-culture related activities, specifically the cultivation of shellfish (Crassostrea gigas), the erection of harvesting equipment and deployment of associated cultivation methods, at Cruit Strand, Kincasslagh Bay, Gweedore, Co. Donegal.
I can confirm that I have studied all relevant documentation pertaining to the above application and I hereby enclose herein details of my reservations with respect to same for your consideration.
Visual Impact:
I support the rights of locals and wildlife, enjoying for generations the tranquillity and unspoilt rural setting, including the unperturbed, pristine waters for which Kincasslagh Bay is renowned. Degrading this rare natural beauty and ecology with the proposed aquafram will threaten the wild ecosystem, tourism and traditions, on which this remote area depends and by which The Rosses is defined.
As the area has remained largely undeveloped, it’s felt that the impact of a large scale proposal such as this, would greatly degrade the area’s unique rural landscape and significant natural habitat.
Oyster farming, as a commercial activity, is specially structured and orientated to take full advantage of the biology and life cycle of the target species. Depending on the methods of cultivation and techniques involved, harvesting of shellfish can cause considerable visual obstruction. The technique favoured by the applicant involves the use of ‘Oyster Trestles’ which, as physical steel structures of varying heights, are easily visible. Additionally, the installation of ‘navigation poles’ along the marine bed which, are designed to be much greater in height than trestles, may also be considered to be unsightly.
In the instance of this application, it’s planned that trestles will be 0.6m in height and 0.7m wide at the top, while the poles have a height specification of 3.5m. Such sizeable frames and poles would be clearly visible in the estuary, particularly during periods of low tide. It may therefore be argued that such a method of cultivation would be considered visually intrusive and would cause significant visual obstruction for both residents and visitors of the area alike.
Environmental Impact:
Considering that the nature of the activities pertaining to the application are primarily marine based, the negative influences often associated with aqua-farming on the marine environment must not be overlooked in this instance.
The area in which this proposal is planned is a Special Area of Conservation (SAC), and any potential aquaculture or mari-culture activity must incorporate specific conditions as to accommodate Natura requirements.
It is widely documented that aquaculture can have a detrimental effect on the marine environment including through the accumulation of waste from feed and faecal pellets, while aquaculture in general may result in changes to the benthic macro-fauna. Aquaculture stock may pose a threat to wild populations through a reduction in gene pool strength caused when escaping farm stock mate with wild species, something which can result in the transmission of diseases to wild stocks. Furthermore, in areas where aquaculture activity is prolific, this is likely to result in environmental degradation and may lead to poor aquaculture growth rates. Therefore, in bays where aquaculture is abundant, the marine environment is likely to suffer from ‘over stocking’.
Furthermore, the potential impact of intertidal oyster culture on water birds and the distribution of any birds which inhabit or depend on water bodies has become the subject of much study in recent years. Research carried out by the Marine Institute into the effects of oyster farming on marine and aquatic birds, has found that the assemblage variation and flocking behaviour of certain bird species is heavily affected by the presence of oyster trestles.
The study found that the species which tend to feed in large highly concentrated flocks, such as the Knot (Calidris canutus); Sanderling (Calidris alba); Dunlin (Calidris alpina); Blacktailed Godwit (Limosa limosa); Bar-tailed Godwit (Limosa lapponica) and the Ringed Plaver (Charadrius hiaticula), all demonstrated a negative response to the structures. The presence of trestles in the samples taken from the studied ordination space, directly interfered with the flocking and territorial behaviour of the species, forcing individual birds to become dispersed across several lines of trestles.[1]
It’s notable that the species which displayed the strongest negative response to oyster trestles generally favour open mudflats/sandflats, such as those present at the proposed development site. Consequently, mixed sediment and rocky shore sites are often cited as the preferred locations for littoral zone oyster culture as such sites can minimise the potential harmful impact of oyster culture on birds inhabiting the marine environment. In this context, it can reasonably be argued that the area for which this licence is being sought would be most unsuitable for the installation of oyster trestles and harvesting equipment given the repercussions which such activities have on avifauna.
In 2014, BirdWatch Ireland and the Royal Society for the Protection of Birds (RSPB) worked to compile a updated list of bird species on the island of Ireland with each species classified into three separate headings (i.e., Red, Amber and Green), based on the conservation status of the bird and hence where conservation priority lies with respect to each.
This publication, entitled ‘Birds of Conservation Concern in Ireland’ (BoCCI) found that, of the above named species, the Dunlin (Calidris alpina) qualified for Red listing due to its extreme declining breeding and wintering populations, while both the Knot (Calidris canutas) and the Bar-tailed Godwit (Limosa lapponica) were given Amber status, owing to the birds’ moderate declines in range and or abundance.[2] In the case of the Dunlin and Knot, coastal estuarine sites of muddy sands, such as those found at the proposed development, are recognised as important wintering sites for both species.
Economic Impact:
Notwithstanding the potential knock-on effects which the awarding of this licence may yield and as discussed previously in this submission, another area to which consideration must be given is that of the impact which such a development may have on the local economy.
Donegal is widely regarded as a land of breath- taking natural beauty and is renowned for its long picturesque coastline, and unspoilt natural habitats. ‘The Beautiful Scenery’ was the main reason tourists cited for choosing to holiday in the county according to tourism studies. In one such study, 80% of respondents credited the ‘Beautiful Scenery’ as their primary reason for recommending the area. These figures therefore serve to highlight the significance of protecting and promoting the topography of the county in order to sustain and further develop the tourism sector here.[3]
Accordingly, it is important to note that poor and imprudent planning and aquaculture management can impact negatively on lucrative recreational activities and amenities such as fishing, water sports and ecotourism to name a few. This is particularly worrying when one considers the importance of the hospitality and tourism sector to the region, something which is largely attributed to its hosting of a number of recreational water based leisure activities such as boating, canoeing, equestrian beach trekking, kayaking, sailing and swimming.
Cruit Strand plays host to many of the above activities thanks by and large to inlet’s relatively shallow waters and the temperate semi-diurnal nature of its tides. This favourable marine environment facilitates the use of the bay for any great number of leisure purposes, many of which have traditionally been enjoyed by locals and visitors to the area alike.
As a result, the strand is understandably a major lure and for visitors when coming to the region, and any development which could potentially restrict or limits its usage for water based leisure activities should be vehemently opposed. Incidentally, the size and scale of the project, as well as the limited ‘Access’ Zone which has been proposed as part of the development, would all but render the strand unsuitable for recreational, sporting and or leisure pursuits.
The tourism industry supports in excess of 29,000 jobs in the region and is responsible for attracting approximately 174,000 overseas visitors each year, while a further 500,000 domestic visitors come to Donegal to enjoy – amongst other things – our clean beaches and waterways.[4]
It may reasonably be argued therefore that should the proposals in question be allowed to go ahead, then such a situation would have profound implications on the locality’s ability to sustain its existing tourism trade on which much employment and local businesses depend and that ultimately, this would irrevocably damage West Donegal’s wider tourism brand.
Accordingly, and notwithstanding the very small number of full and part-time jobs which the applicant intends to create as a direct result of their application, the resulting job losses which would arise in both the tourism and hospitality industries would subsequently negate any potential job creation which the project may yield, and would ultimately result in significant employment loss to the area.
In conclusion, my observations regarding the aforementioned application are set out and outlined herein for the due consideration of the Minister concerned.
Signed:
__________________
COMMENTS
________________________________________________________________________________________________________________________________________________________________________________________________
[1] Gittings, T. & O’Donoghue, P.D. (2012). The effects of intertidal oyster culture on the spatial distribution of waterbirds. Report prepared for the Marine Institute. Atkins, Cork.
[2] Colhoun, K. and Cummins, S. (2014) Birds of Conservation Concern in Ireland 2014–2019.
[4] Donegal County Council, (2014), “DONEGAL’S TOURISM PRODUCT DEVELOPMENT.” Accessed October 03, 2016. http://www.donegalcoco.ie/business/developingourtourismsector/.
TEMPLATE FOR KEADUE STRAND REF: T12/474 A & B
Aquaculture and Foreshore Management Division,
The Department of Agriculture,
Food and the Marine,
Clogheen,
Clonakilty,
Co. Cork.
6th October 2016
A Chara,
Case reference: T12/474 A & B
I am writing to make a formal observation, pursuant to Regulation 9 of the Aquaculture (Licence Application) (Amendment) Regulations 2012, with respect to the Aquaculture licence application cited above. The applicant (Mr. Manus Bonnar, Belcruit, Kincasslagh, Co. Donegal) is seeking permission to carry out a number of Marine-based and Mari-culture related activities, specifically the cultivation of shellfish (Crassostrea gigas) and the erection of harvesting equipment and deployment of associated cultivation methods, at Keadue Strand, Kincasslagh Bay, Kincasslagh, Co. Donegal.
I can confirm that I have studied all the relevant documentation pertaining to the above application. As part of the Irish Diaspora, I hereby enclose herein details of my reservations with respect to same for your consideration.
Visual Impact
As part of the Irish Diaspora I support the rights of locals, visitors and wildlife, enjoying for generations the tranquillity and unspoiled rural setting, including the unperturbed, pristine waters for which Kincasslagh Bay is renowned. Degrading this rare natural beauty and ecology with the proposed aquafarm will threaten the wild, biodiverse ecosystem; tourism; and traditions, on which this remote area depends and by which The Rosses is defined.
As the area has remained largely undeveloped it’s felt that the impact of a large scale proposal such as this, would greatly degrade the area’s unique rural landscape and significant natural habitat.
Oyster farming, as a commercial activity, is specially structured and orientated to take full advantage of the biology and life cycle of the target species. Depending on the methods of cultivation and techniques involved, harvesting of shellfish can cause considerable visual obstruction. The technique favoured by the applicant involves the use of ‘Oyster Trestles’ which, as physical steel structures of varying heights, are easily visible. Additionally, the installation of ‘navigation poles’ along the marine bed which, are designed to be much greater in height than the trestles, may also be considered unsightly.
In the instance of this application, it’s planned that trestles will be 0.6m in height and 0.8m wide at the top. Such sizeable frames and poles would be clearly visible in the estuary, particularly during periods of low tide. It may therefore be argued that such a method of cultivation would be considered visually intrusive and would cause significant visual obstruction for both residents and visitors to the area alike.
Environmental impact:
Considering that the nature of activities pertaining to the application are primarily marine based the negative influences often associated with aqua-farming on the marine environment must not be overlooked in this instance.
The area in which this proposal is planned is a Special Area of Conservation (SAC), and any potential aquaculture or mar-culture activity must incorporate specific conditions as to accommodate Natura 2000 requirements.
It is widely documented that aquaculture can have a detrimental effect of the marine environment including through the accumulation of waste from feed a faecal pellets, while aquaculture in general may result in changes to the benthic macro-fauna. Furthermore, aquaculture stock may pose a threat to wild populations through a reduction in gene pool strength cased when escaping farm stock mate with wild species, something which can result in the transmission of diseases to wild stocks.
In areas where aquaculture activity is prolific, this is likely to result in environmental degradation and may lead to poor aquaculture growth rates. Therefore, in bays where aquaculture is abundant, the marine environment is likely to suffer from ‘over stocking’.
Notwithstanding this, it is important to note that poor and imprudent planning and management of aquaculture can also impact negatively on lucrative recreational activities and amenities such as fishing, water sports and ecotourism to name a few.
In conclusion, my observation regarding the aforementioned application are set out and outlined herein for the due consideration of the Minister concerned.
Signed:
_____________________________________
COMMENTS
__________________________________________________________________________________________________________________________________
[4] Donegal County Council, (2014), “DONEGAL’S TOURISM PRODUCT DEVELOPMENT.” Accessed October 03, 2016.http://www.donegalcoco.ie/business/developingourtourismsector/.
Tinteán 