Lough Foyle Consultation
13 June 2005 Mr J Pollock
Loughs Agency
22
Victoria Road
Londonderry
BT47 2AB Dear John RE-
DRAFT IMPLEMENTATION PLAN FOR THE DEVELOPMENT OF SHELL FISHERIES AND AQUACULTURE OF LOUGH FOYLE Thank
you for the opportunity to comment on the above consultation paper. Council
believes that from a marine perspective this document represents a constructive step forward, and we
welcome the clear statements on page 11in respect of the designated areas of the lough and their requirements.
This is extremely important, given the international importance of these areas, and indeed the key role
they play at a local level in the lough. We also welcome the proposals for closer management of the
lough's shell fisheries - the problem with the management of many marine areas is what has been called
'The tragedy of the commons' with unregulated traditional exploitation exceeding the ability of the
resource to sustain itself. In respect of subtidal habitats, the most interesting
area is at the mouth of the Lough which seems to be considered mainly as a spat recruitment area rather
than one for intensive fishing. We would be concerned about the anthropomorphic
definitions of sustainability (page 5) and particularly that for environmental sustainability on page
6. A recognition in the document that sustainability can only be achieved if economic, social and environmental
factors are in balance, would go some way to address this concern. We are concerned
that the Agency is minded to only regulate aquaculture proposals on a reactive basis (sections 7.4 and
4.4.3). This approach has been beset with problems in other areas and is likely to result in failure
of any approach to sustainable development. We strongly recommend the preparation of a plan that will
address the carrying capacity of the lough in ecological and ICZM terms, or at the very least a clear
set of principles by which applications may be judged. We would also recommend relating this to the
wider N Ireland Aquaculture Strategy currently being prepared by Fisheries Division. In this, a key
element is consideration of overall carrying capacity, which incorporates the demands by natural ecosystems
as well as potential aquaculture uptake, and in respect of Lough Foyle this may require research before
a definitive position can be taken up. We welcome the statement, and recognition
of the importance of ICZM as a tool for managing coastal areas like Lough Foyle - hence our comments
in the bullet point above. Council finds that the document, for whatever reason,
considers that everything in the sea is still perceived as a 'resource' for the fishing industry or
as a food source for potential aquaculture growth. We take the view that conserving the 'Environment'
is about not destroying the resource (for fishing) or reducing the quality of that environment for a
far wider range of reasons, - this could be related to our point above about sustainability, and certainly
would be required under the Lough's status as a Natura 2000 site. Despite all
the foregoing we believe that most of the conclusions reached are correct and the proposals for the
way forward are to be encouraged. The only caveat we would add is that development
of intensive aquaculture, though not an apparent problem at the moment, would need to be very carefully
monitored hope you find these points of use, but we would welcome further discussion,
and possibly a presentation, with you at CNCC when you have considered the outcome of your consultation. Yours
sincerely Dr Lucinda Blakiston Houston
Chairman
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