A licence to Industrially Extract 1860 acres of Native Kelp in Bantry Bay has been issued to BioAtlantis, Tralee.
NO Public Consultation took place. This licence was NOT Advertised Adequately. This licence has been issued with NO requirement for an Environmental Impact Assessment [E.I.A.]
This is the largest industrial scale native Kelp Extraction Licence ever issued in Irish or British waters.
Summary: Prepared by: Tomás O’Sullivan, PhD (email@example.com)
6 June 2017
The two primary areas of concern, at present, are:
Archaeological excavation has revealed the presence of a significant Viking site at Lonehort Harbour, on the south-east of Bere Island. Known remains include:
Lonehort Harbour is the only portion of shoreline on south-eastern Bere Island to be excluded from the Licence Area, presumably because of these archaeological remains (see points 34 & 35 on Licence Map). Nonetheless, a known site of Viking maritime activity lies right in the midst of Licence Area E2. It is highly probable that undiscovered Viking-age remains may be encountered along the shoreline or upon the foreshore and/or seabed in Licence Area E2.
See further: ‘1995:022 - Lonehort Harbour, Ardnaragh East, Bere Island, Cork’ (Excavation summary on excavations.ie): http://www.excavations.ie/report/1995/Cork/0001864/ (accessed 06/06/17). John Sheehan, ‘Viking harbour at Lonehurt [sic], Bere Island, Co. Cork, 1995’ (Technical publication: 1996).
All shipwrecks over 100 years old are classed as national monuments, and are protected by the National Monuments (Amendment) Act 1987. It is an offence to ‘tamper with, damage, or remove any part of the wreck or archaeological object’, or to cause ‘anything’ to fall ‘on to the sea bed’ which ‘would wholly or partly obliterate the site or obstruct access to it, or damage any part of the wreck or object’.
There are at least thirteen documented shipwrecks over 100 years old within Licence Area E2 and Licence Area E1, and five further documented shipwrecks over 100 years old within the vicinity of Licence Area D.
One of the most notorious locations for shipwrecks in the vicinity of Berehaven is identified in the sources as Carraig na Madraí or Dog Rock, today known as Carrigavaddra Perch (51° 38.670'N 009° 46.330'W), and, perhaps, the associated reef. This rock appears to be identified as ‘Perch Rock’ on the Licence Map (the name is slightly obscured), to the southwest of the map’s points 28 and 29: within Licence Area E2. Although the precise location of each wreck has yet to be identified, there are at least twelve documented shipwrecks on this rock which occurred over 100 years ago:
Source: Donal Boland, ‘Appendix E: Archaeology Survey Report’, DJBMA Report 01-06-05, Licence No.05R0072 (June 2005), Appendix I (pp. 30-42).
The Leon, a ship out of Rouen under Captain Esclapon, was carrying a cargo of brandy and wine. Unable to enter Berehaven on 29 April 1842, due to south-east gales, she anchored off of Faoch Rock, but her anchor dragged, and she is recorded as having been wrecked at the ‘E[ast] end of Carraig Grianán, Bere Is.’ All hands were lost.
Faoch Rock lies north-east of point 32 on the Licence Map, and Carraig Grianán, or Greenane Rock, lies just south-east of point 33, both within the Licence Area: the wreck of the Leon, east of Greenane Rock, is therefore located inside Licence Area E1.
Source: Donal Boland, ‘Appendix E: Archaeology Survey Report’, DJBMA Report 01-06-05, Licence No.05R0072 (June 2005), Appendix I (pp. 30-42), at p. 36. Citing Ted O’Sullivan, Bere Island: A Short History (Cork: Inisgragy Books, 1992), p. 67; and The National Folklore Collection, Schools’ Collection, Imleabhar 277, pp. 115-116.
While the precise locations of each of these wrecks has yet to be identified, there are at least five documented shipwrecks over 100 years old on the Roancarrig Rocks, and thus within, or in the vicinity of, Licence Area D:
Sources: Daniel Boland, ‘Marine Geo-archaeological Assessment: Proposed Fish-farm Site, Shot Head, Bantry Bay, Co. Cork’, DJMBA Report 01-06-12, Licence No. 12R72 (June 2012), §3.1.5 (pp. 21-22 and Table 4); Donal Boland, ‘Appendix E: Archaeology Survey Report’, DJBMA Report 01-06-05, Licence No.05R0072 (June 2005), Appendix I (pp.
MSP/ ICZM / EIA – Out the Window in Bantry Bay
The case for proactive research before Coastal & Marine Decision-Making (in West Cork)
MSc Coastal & Marine Environments
MSc GIS & Remote Sensing
Ba Geography & Economics
Developer - Openlittermap.com
The oceans of our only habitable planet are essential ecosystems for the survival of life that provide a diverse suite of ecosystem services to humans including adding value to economic growth that represented a contribution of an estimated €1.4 billion to Irish GDP including employing 18,500 Full-time equivalents in 2014 (Marine Institute, 2015) and about €500 billion to the annual EU economy (European Commission, 2017).
“Blue growth” i.e. the sustained and inclusive development of coastal and marine territory is expected to undergo significant economic development in this generations lifetime and provide additional value to economic recovery, general well-being and livelihood. In order for this growth to be sustained for current and future generations, proactive research is needed to ensure that this is done in a responsible, sustainable, fair and balanced manner that is inclusive of the competing needs of multiple different stakeholders. Failing to address or engage with scientific investigation has resulted in dramatic and irreversible economic and ecosystem collapse. For example, in 1992, the collapse of the Canadian Cod fisheries (Fig. 1), once renowned as the world’s most productive fishing grounds, was devastated by incompetent mismanagement of overly-efficient and largely untested new technology that almost immediately put an estimated 40,000 people out of work resulting in a multi-billion dollar emergency relief package for coastal communities and a 2-year moratorium on fisheries that is still in place today, over 20 years later. This “Ecoside” could possibly have been avoided, if management had engaged with and took the advice of academics and respected the natural stocks ability to respond to industrial harvesting and better understood the potential for “tropic cascade” (Fig. 2) caused by removing an integral and/or indirect component(s) of an ecosystem(s).
Fig 1. “Canadian Fisheries Cod Collapse” – 40,000 people out of work in 1992.
Fig 2. “Trophic Cascade” – in this schematic one can observe the impact that the removal of one component (Sea otter) had on multiple different and related parts of the ecological system in California.
In order for “Blue Growth” to be sustainable, fair and balanced, stakeholders must be able to share their concerns early to avoid potentially irreversible economic, ecological or livelihood collapse. Integrated Coastal Zone Management (ICZM) and Marine Spatial Planning (MSP) are inclusive decision-making processes for the coastal zone and marine space that attempt to deal with the multiple, diverse, overlapping and often competing needs and demands of multiple different stakeholders and local communities. While ICZM bridges the gap between terrestrial and marine planning, MSP is more exclusively concerned with maritime activities. However, both practices share common practices, such as involving different stakeholders in dialogue and finding ways to balance the distribution of human activities across space and time to achieve economic, social, ecological and environmental objectives. By drawing upon and/or generating the best available science, it is possible to geospatially, quantitatively, qualitatively, responsibly and fairly coordinate human uses and activities for sustainable long-term economic growth however this process must be inclusive and allow stakeholders to share their concerns early before licenses are issued. Failure to do so is entirely irresponsible. Many activities are already managed in coastal and marine space such as transportation, aquaculture, fishing, bathing, renewable energy development, resource mining and coastal development and this process should remain ongoing, inclusive, open and iterative.
Kelp, of which 1,860 acres has been licensed in Bantry Bay (Fig. 3) to industrially harvest with no Environmental Impact Assessment, no public and stakeholder consultation. Despite this, kelp forests have been described as some of the most ecologically dynamic and biologically diverse habitats on the planet with primary production among the highest in aquatic ecosystems and can be considered as “keystone species” which are important for the survival of many other different species (Birkett et al. 1998; NPWS, 2005). Not only do kelp provide important nursery and feeding grounds while anchored to the seafloor, but once naturally washed on shore they provide similarly important habitat for a variety of different migratory bird and various insect species. Undoubtedly, the removal of large swaths of kelp forest will result in direct and indirect ecosystem cascades elsewhere and these interactions should be attempted to be modeled and understood before significant machine harvesting can be licensed. Unfortunately, the biodiversity of Irish kelp and their significance for marine ecology is quite poorly documented and often overlooked and misunderstood. For example, although we are a relatively small peripheral island nation on a largely oceanic planet, marine ecology and marine science are not yet available as an integral part of the contemporary education system despite the ocean covering over 70% of the surface of the planet and providing every second breath of oxygen we breath. However, this lack of data provides room for exciting areas of research and investment. Ireland (West Cork in particular which enjoys some of Ireland’s cleanest coastal waters) could take advantage of these spectacular natural resources and pioneer ourselves as custodians of our only habitable planet and become a beacon for marine ecologists and sustainable tourism and provide the gold standard for sustainable educational tourism, scientific courses and educational summer camps for the long-term, which would be a sustainable source of income and responsible ecotourism for future generations.
Fig 3. Map of 1,860 areas licensed to industrially harvest native kelp forest without public or stakeholder consultation or EIA.
Through the Convention of Biological Diversity (CBD, 2010) Ireland is required to designate at least 10% of its coastal and marine territory “especially areas of particular importance for biodiversity and ecosystem services” as a Marine Protected Area (MPA) by 2020 however currently less this figure is ~2% because of contemporary government ineptitude and a basic lack of geospatial data. Ireland is also legally required to implement the EU Marine Strategy Framework Directive (MSFD) that legally requires an “all-encompassing ecosystems-based approach to resource management” (EBRM) which by definition requires investigation into all of the components of an ecological system and should be representative of the ecological connections and inter-relationships of MPA’s and/or important marine areas. As well as native species, islands and coastal regions are the most threatened by invasive alien species that should also be factored into an EBRM (iDiv, 2017).
Climate change must also be factored into the equation, which is predicted to result in increased levels of water temperature, acidity and changes and rises in wave heights and storm surges to coastlines as well as changes in the timing and abundance of rainfall. In this respect, kelp offers the first hope of defense for coastal communities and significant critical infrastructure by taking the brunt impact of wave action and trapping sediment. Significantly greater research is need to understand how important kelp is for the local economy particularly in terms of how it can provide an ecosystem service as a coastal defense and mitigate wave action to prevent against coastal erosion which can cost between €0.7 and €6 million per kilometer for protection let alone insurance, repair and opportunity cost for coastal economies (Engineers Journal, 2017).
Birkett, D. A., Maggs, C. A., Dring, M. J., Boaden, P. J. S. and Seed, R. (1988). Infralittoral reef biotopes with kelp species (volume VII). An overview of dynamic and sensitivity characteristics for conservation management of marine SACs. Scottish Association of Marine Science (UK Marine SACs Project). 174pp.
Blue Growth, European Commission (2017); https://ec.europa.eu/maritimeaffairs/policy/blue_growth_en
iDiv (German Center for Integrative Biodiversity Research, 2017); Islands and Coastal Regions and Threatened the most [By alien species]; https://www.idiv.de/news/news_single_view/news_article/islands-and.html
Marine Institute (2014); Report on Ireland’s Ocean Economy Launched
NPWS (2005); The Role of Kelp in the Marine Environment
"I can only compare these great aquatic forests of the southern hemisphere with the terrestrial ones in the inter-tropical regions. Yet if in any country a forest was destroyed, I do not believe nearly so many species of animals would perish as would here, from the destruction of the kelp
Amidst the leaves of this plant numerous species of fish live, which nowhere else could find food or shelter; with their destruction the many cormorants and other fishing birds, the otters, seals, and porpoises, would soon perish"
~ Charles Darwin