Application by Marine Harvest Ireland for a Salmon Farm Development at Shot Head, Bantry Bay, County Cork. Reference T5/555. Additional Information

Transcription

1 Watermark 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 Client Marine Harvest Ireland Rinmore Letterkenny County Donegal telephone +353 (0) mobile +353 (0) neilbass@iol.ie

2 Application by Marine Harvest Ireland for a Salmon Farm Development at 2. Application by Marine Harvest Ireland for a Salmon Farm Development at Shot Head, Bantry Bay, County Cork. Reference T5/555 Additional Information February Executive Summary.

3 Application by Marine Harvest Ireland for a Salmon Farm Development at 3. Application by Marine Harvest Ireland for a salmon farm development at Shot Head, Bantry Bay, County Cork, reference T5/555. Additional Information Executive Summary. 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 The Marine Institute (MI) were required by DAFM to review the application and EIS towards the end of 2013, resulting in the issuing of a report from the MI in January 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 , the European Communities (Control of Dangerous Substances in Aquaculture) Regulations 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 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 S0 stock, in December There have also been three Hydrogen Peroxide (H 2 O 2 ) lice treatments in Bantry Bay in the same period but, since the breakdown products of H 2 O 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.

4 Application by Marine Harvest Ireland for a Salmon Farm Development at 4. 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 210,800m 2, 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 600m 3 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 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 ng/l under mean neap tide

5 Application by Marine Harvest Ireland for a Salmon Farm Development at 5. conditions and ng/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.

6 Application by Marine Harvest Ireland for a Salmon Farm Development at 6. Application by Marine Harvest Ireland for a Salmon Farm Development at Shot Head, Bantry Bay, County Cork. Reference T5/555. Additional Information February Main Report.

7 Application by Marine Harvest Ireland for a Salmon Farm Development at 7. Application by Marine Harvest Ireland for a salmon farm development at Shot Head, Bantry Bay, County Cork, reference T5/555. Additional Information. Main Report. Section 1. Introduction. Marine Harvest Ireland (MHI) applied to the Aquaculture and Foreshore Management Division (AFMD) of the Department of Agriculture, Food and the 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 As required, the application was accompanied by an Environmental Impact Statement (EIS). In due course, the application was accepted by the Department and assigned the reference number T5/555. Public advertisement of the application, along with internal, public and statutory consultations took place in the months following, under the terms of SI , the Aquaculture (Licence Application) Regulations, It is understood that, following instruction from the Department, the Marine Institute (MI) reviewed the application and the EIS towards the end of This resulted in the issuing of a report from the MI, which was made available to MHI in January Arising from the MI report, a request for further information was communicated to MHI by the Department on 10th February 2014; see Appendix 1. Details of the further information required are set out in Appendix 2. Under the terms of SI , the European Communities (Control of Dangerous Substances in Aquaculture) Regulations 2008, a licensing authority cannot consider the grant of an Aquaculture Licence unless dangerous substances, as defined, are identified and their use adequately quantified in the application documentation. In this case, the additional information request observes that, whilst the EIS provides adequate information on the type and nature of the dangerous substances to be used as sea lice treatments, and their intended method of application, there is insufficient information / data on the likely quantity and frequency of discharges of these substances. Furthermore, the EIS has not adequately demonstrated compliance with the Environmental Quality Standards (EQS's) for these substances, as required by SI 466. The EQS's in question are attached, in Appendix 3. From this list MHI understands that further information must be provided on the use and possible impacts, if any, of the sea lice treatments Slice (active ingredient Emamectin Benzoate; EmBZ) and Alphamax (active ingredient Deltamethrin). The purpose of this document is to respond to the queries raised by the request for further information.

8 Application by Marine Harvest Ireland for a Salmon Farm Development at 8. Section 2. Sea lice and sea lice treatment in Bantry Bay 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 Sea lice monitoring in Bantry Bay As 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 MI since This program also forms the basis of a statutorily required treatment regime. Under the May 2000 protocol 1, 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 MI. The results of the MI national sea lice surveys are published annually and can be found on the MI website. The MI 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 MI'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. 1 Monitoring Protocol No. 3 for Offshore Finfish Farms - Sea Lice Monitoring and Control. DCMNR, May 2000.

9 Application by Marine Harvest Ireland for a Salmon Farm Development at 9.

10 Application by Marine Harvest Ireland for a Salmon Farm Development at 10.

11 Application by Marine Harvest Ireland for a Salmon Farm Development at 11. Section 3. Characterising and quantifying a lice treatment regime for Shot Head 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, S0 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 The only other sea lice treatments carried out were a series of three, using a total of 52,200l of Hydrogen Peroxide, on older fish. There has never been an Alphamax treatment on MHI's Bantry Bay sites 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.

12 Application by Marine Harvest Ireland for a Salmon Farm Development at 12. Watermark February 2014.

13 Application by Marine Harvest Ireland for a Salmon Farm Development at 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 50µg 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.

14 Application by Marine Harvest Ireland for a Salmon Farm Development at 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 well boat tanks for Alphamax treatments. Treatment dosage and duration is 0.2ml Alphamax (= 2µg Deltamethrin) per m 3 seawater in the well tank for minutes. See SOP 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 600m 3 tanks. These would require a total dose of 120ml of Alphamax, containing 1,200µg (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 2,400µg of Deltamethrin) per 4- hour treatment cycle, or a total of 6,720ml of Alphamax (or 67,200µg of Deltamethrin) for the full treatment of 2,800 tonnes of fish over 4.67 days.

15 Application by Marine Harvest Ireland for a Salmon Farm Development at 15. Section 4. Waste loadings, dispersal and fate of EmBZ and Deltamethrin treatments 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:- M T = M 0 x e (x * T) Where M 0 = mass of EmBZ in the fish prior to its excretion M T = Mass of EmBZ excreted at time T T = time x = excretion rate factor, determined to be 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, Regulation and monitoring of marine cage fish farming in Scotland. Annex H; Methods for modelling in-feed antiparasitics and benthic effects.

16 Application by Marine Harvest Ireland for a Salmon Farm Development at 16. 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 mg 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.

17 Application by Marine Harvest Ireland for a Salmon Farm Development at 17. 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 210,800m 2. 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. 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; ng/l), daily mean concentrations are given, along with the value 48 hours post-treatment. This shows that the peak value of 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. 3 Edwards A, Sharples F Scottish Sea lochs; a catalogue. SMBA/NCC 110pp

18 Application by Marine Harvest Ireland for a Salmon Farm Development at 18.

19 Application by Marine Harvest Ireland for a Salmon Farm Development at 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, topdressed 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 than 0.196ng/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 ng/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 Settlement study; Shot Head, Bantry Bay.

20 Application by Marine Harvest Ireland for a Salmon Farm Development at 20. 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/m 3, 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.

21 Application by Marine Harvest Ireland for a Salmon Farm Development at 21.

22 Application by Marine Harvest Ireland for a Salmon Farm Development at 22.

23 Application by Marine Harvest Ireland for a Salmon Farm Development at 23.

24 Application by Marine Harvest Ireland for a Salmon Farm Development at 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 of fish 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).

25 Application by Marine Harvest Ireland for a Salmon Farm Development at 25.

26 Application by Marine Harvest Ireland for a Salmon Farm Development at 26.

27 Application by Marine Harvest Ireland for a Salmon Farm Development at 27. 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 ng/l under mean neap tide conditions and ng/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 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 600m 3 wells in the Grip Transporter well boat), would require 120ml of Alphamax, containing 1,200µg (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 ng/ng/l, in mean neap tide conditions, and ng/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 of reasons:-

28 Application by Marine Harvest Ireland for a Salmon Farm Development at 28. 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 The Marine Institute (MI) were required by DAFM to review the application and EIS towards the end of 2013, resulting in the issuing of a report from the MI in January 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 , the European Communities (Control of Dangerous Substances in Aquaculture) Regulations 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 Settlement study; Shot Head, Bantry Bay.

29 Application by Marine Harvest Ireland for a Salmon Farm Development at 29. 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 S0 stock, in December There have also been three Hydrogen Peroxide (H 2 O 2 ) lice treatments in Bantry Bay in the same period but, since the breakdown products of H 2 O 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 210,800m 2, 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 600m 3

30 Application by Marine Harvest Ireland for a Salmon Farm Development at 30. 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 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 ng/l under mean neap tide conditions and ng/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.

31 Application by Marine Harvest Ireland for a Salmon Farm Development at 31. Appendices

32 Application by Marine Harvest Ireland for a Salmon Farm Development at 32. Appendix 1 Request for further information 1. Letter from K. Hodnett, DAFM, to J Feenstra, MHI.

33 Application by Marine Harvest Ireland for a Salmon Farm Development at 33.

34 Application by Marine Harvest Ireland for a Salmon Farm Development at 34.

35 Application by Marine Harvest Ireland for a Salmon Farm Development at 35. Appendix 2 Request for further information document. Marine Harvest Ireland Application for a Salmon Farm Development in Bantry Bay (Shot Head) Additional Information.

36 Application by Marine Harvest Ireland for a Salmon Farm Development at 36.

37 Application by Marine Harvest Ireland for a Salmon Farm Development at 37.

38 Application by Marine Harvest Ireland for a Salmon Farm Development at 38. Appendix 3. Request for further information Environmental Quality Standards for sea lice treatments. In accordance with SI European Communities (Control of Dangerous Substances in Aquaculture) Regulations 2008.

39 Application by Marine Harvest Ireland for a Salmon Farm Development at 39.

40 Application by Marine Harvest Ireland for a Salmon Farm Development at 40. Appendix 4. Marine Harvest Ireland Special Operating Procedures (SOP's) relating to sea lice treatment. 1. SOP Version 002. Lice monitoring. 2. SOP Version 002. Sea lice treatment with Slice. 3. SOP Version 004. Alphamax treatment in well boats. 4. SOP Version 002. Hydrogen peroxide treatment in tarpaulin. 5. SOP Version 002. Hydrogen peroxide lice treatment in well boat. 6. SOP Version 001. Sea lice treatment rotation.

41 Application by Marine Harvest Ireland for a Salmon Farm Development at 41.

42 Application by Marine Harvest Ireland for a Salmon Farm Development at 42.

43 Application by Marine Harvest Ireland for a Salmon Farm Development at 43.

44 Application by Marine Harvest Ireland for a Salmon Farm Development at 44.

45 Application by Marine Harvest Ireland for a Salmon Farm Development at 45.

46 Application by Marine Harvest Ireland for a Salmon Farm Development at 46.

47 Application by Marine Harvest Ireland for a Salmon Farm Development at 47.

48 Application by Marine Harvest Ireland for a Salmon Farm Development at 48.

49 Application by Marine Harvest Ireland for a Salmon Farm Development at 49.

50 Application by Marine Harvest Ireland for a Salmon Farm Development at 50.

51 Application by Marine Harvest Ireland for a Salmon Farm Development at 51.

52 Application by Marine Harvest Ireland for a Salmon Farm Development at 52.

53 Application by Marine Harvest Ireland for a Salmon Farm Development at 53.

54 Application by Marine Harvest Ireland for a Salmon Farm Development at 54.

55 Application by Marine Harvest Ireland for a Salmon Farm Development at 55.

56 Application by Marine Harvest Ireland for a Salmon Farm Development at 56.

57 Application by Marine Harvest Ireland for a Salmon Farm Development at 57.

58 Application by Marine Harvest Ireland for a Salmon Farm Development at 58.

59 Application by Marine Harvest Ireland for a Salmon Farm Development at 59.