Humpback feeding on sprat in Dingle Bay

Razorbill feeding on sprat in Dingle Bay

Forage Fish: Little Fish with a Big Impact [Pew]

It is very easy to promote the conservation of "film-star species" like basking shark, humpback whales, bluefin tuna, salmon, puffins etc., but it takes a lot more effort and fundamental knowledge and appreciation of how our marine ecosystems work to actively promote the conservation and protection of keystone species that support the very base of the food chain and our reliance on some keystone species like phytoplankton for 30% of the oxygen in the very air that we breath. (Oceanic sources produce about 50% of the overall oxygen in the earth's atmosphere, but there are also residual oxygen resources from millions of years and of course other marine fauna also use up oxygen).

These keystone species urgently need legal protection and conservation by eNGOs, possibly more so than the "film-star species", including the many and varied and fascinating (under the microscope) species of zooplankton, copepods and krill which are currently being industrial-scale fished and over-exploited in the Antarctic, often by European fishing vessels and accompanying factory ships; the equally fascinating and beautiful sand eels, which are actually lance fish with eel-like, long, slender, silver bodies and pointed snouts (all the better for burying themselves in the sand) and extendable, protrusile lower jaws by which they can form a tube equalling their own body girth; and our currently over-exploited but ecologically very important stocks of sprat, pilchards and newcomers anchovies which are now moving further north into our Irish inshore waters along with the "film-star species" like blue-fin tuna, which are of course protected in Irish waters, with no fishing quotas for the Irish fishing fleet and 100% of the blue-fin tuna quotas in European waters, including Irish waters, taken up by other EU fishing boats and outside our 200 mile European Economic Zone Japanese trawlers can fish for them unrestricted.

I have included below the wonderful poem by the Scottish poet Robert Burns "To a Mouse" (Apodemus sylvaticus?) On Turning Her Up in Her Nest with the Plough, November, 1785 (almost 240 yrs. ago!) with particular reference to the second verse. Unfortunately, "Nature's social union" is no longer relevant to Irish agricultural farming, and the nitrogen-green deserts of fertiliser-fed ryegrass that are now ubiquitous in the Irish landscape.

These nitrogen-green fields of ryegrass are effectively green deserts in the Irish landscape, far from the "forty shades of green" of the Johnny Cash ballad of natural pasture land, as can be ascertained by making a scientifically correct appraisal of the earth worm population in the subsoil which should be approximately 500,000 earthworms per acre for a healthy soil. [Charles DarwIn was wrong in his assessment of approx. 50,000 earthworms per acre in a healthy acre of land.] The easiest way to make this appraisal is to dig a 1 square meter area of the topsoil as a sample area, or a number of these sample areas, take the average count of earthworms in a 1 square meter area and multiple that by 4047.  Most of these nitrogen green ryegrass deserts are dead zones underneath the soil and grass production is only viable by adding artificial fertiliser containing nitrogen (N), phosphorous (P) and potassium (K) and eventually, over time, and generations, these grassland will fail and become real deserts just like the "Cáide fields" in West Mayo 


Let's hope that the same type of sterile, underwater, marine environment is not allowed to happen in our rich, biodiverse, Irish inshore waters, as has happened in our pasturelands and eradicated hedgerows and woodlands. 

The poem below is written by the famous Scottish national poet Robert Burns at the start of the Agricultural Revolution which just preceded the Industrial Revolution and in some sense the little  "mousie" in the poem represents the dispossessed Scottish farmers that were  the victims of that agricultural and industrial revolution that followed and continues to the present day. This was the beginning of the end of the natural world and humans living in balance and harmony with the natural world of which we are a small part, and leading up to the present day Big Agriculture and Big Fishing, which have basically declared war on nature and our environment, including its natural flora and fauna

This poem is written in a rich, vernacular, Scottish dialect which may be difficult for modern readers used to anglicised literature to understand and I would suggest reading the verses out loud to appreciate the rich verbosity and deep feeling of regret for the past and apprehension for the future in the poem.

Good luck (!) and if at first you don't succeed, try again.


                                                                  Ode To a Mouse
                                                                      by Robert Burns

On Turning Her Up in Her Nest with the Plough, Novenber, 1785

Wee, sleekit, cowrin, tim'rous beastie,
O, what a panic's in thy breastie!
Thou need na start awa sae hasty,
Wi' bickering brattle!
I wad  be laith to rin an' chase thee,
Wi' murdering pattle!

I'm truly sorry Man's dominion
Has broken Nature's social union,
An' justifies that ill opinion
Which makes thee startle
At me, thy poor, earth-bound companion
An' fellow-mortal!

I doubt na, whyles, but thou may thrieve;
What then? Poor beastie, thou maun live!
A daimen-icker in a thrave
'S a sma' requet;
I'll get a blessin wi' the lave,
An' never miss't!

Thy wee-bit housie, too, in ruin!
Its sily wa's the win's  are strewin!
An' naething, now, to big a new ane,
O' foggage green!
An' bleak December's win's ensuing,
Baith snell an' keen!

Thou saw the fields laid bare an' waste,
An' weary Winter comin fast,
An' cozie here, beneath the blast,
Thou thought to dwell,
Till crash! The cruel coulter past
Out thro' thy cell.

That wee bit heap o' leaves and stibble,
Has cost thee monie a weary nibble!
Now thou's turned out, for a' thy trouble, 
But house or hald,
To thole the Winter's sleeky dribble,
An' cranreuch cauld!

But Mousie, thou art no thy lane,
In proving foresight may be vain:
The best-laid schemes o' Mice an' Men
Gang aft agley,
An' lea'e us nought but grief an' pain,
For promis'd joy!

Stil thou are blest, compared wi' me!
The present only toucheth thee:
Bot Och! I backward cast my e'e,
On prospects drear!
An' forward, tho' I cannot see,
I guess an' fear!


Below is an anglicised version of the same poem, which I am loath to call a "translation", as  some poems and works of art are untranslatable. The particular power of this poem is in the language as well as in the message. Some poems in the Irish language are also similarly untranslatable, as in "Caoineadh Airt Uí Laoghaire"  [ "The Lament for Art ó Laoghaire"] where the power of the poem lies in the language and the delivery.

This "translation" is provided to help the reader understand the meaning of the words in the original and then go back and read the original poem with greater understanding and appreciation of the language. The poem also masks many hidden meanings and feelings in it's apparent simplicity of delivery and subject matter.


Ode To a Mouse by Robert Burns
( "translated " by Michael E Sheeran) 

On Turning Her Up in Her Nest with the Plough, November, 1785

Wee, sleek, cowering, timorous, beastie,
O, what a panic's in thy breastie!
Thou need not start away so hasty,
With bickering brattle!
I would be loath to run and chase thee,
With the murdering pattle! *

I'm truly sorry Man's dominion
Has broken Natures social union,
And justifies that ill opinion
Which makes thee startle
At me - thy poor, earth-born companion
And fellow-mortal!

I doubt not, whilst thou may thieve;
What then? Poor beastie, thou must live!
An odd ear of corn in the corn-stack
Is a small behest;
I'll get a blessing with the leavings
And never miss it!

Thy wee-bit housie, too, in ruins!
It's fragile walls the winds are strewing!
And nothing left now, to build a new one
Of coarse, green grass!
And bleak December's winds ensuing
Both sharp and keen!

Thou saw the field laid bare and waste,
And weary Winter coming fast,
And cozy here, beneath the blast,
Thou thought to dwell.
Till crash! The sharp plough-share passed
Clean thru' your cell.

That wee bit heap of leaves and stubble,
Has cost thee many a weary nibble!
Now you are turned out, for all your trouble,
Without house or household
To endure the Winter's sleety drizzle
And white hoarfrost!

But Mousie, thou art not alone,
In proving foresight may be vain;
The best-laid schemes of Mice and Men
Oft' gang awry,
And leave us nought but grief and pain,
For promised joy.

Still thou art blest, compared with me!
The present only touches thee;
But Och! I backward cast my eye,
On prospects drear!
And forward, though I cannot foresee,
I worry and I fear!

* "pattle" - a long, hoe-like, farm tool used to clean heavy clods of clinging, wet, earth from the ploughshare blades.

---

Ban on industrial fishing for "sprat" in Irish 6 Nautical Mile Zone and Baselines (including sprat, pilchards, anchovy, sardines, sand eels) for all sea-fishing trawlers within the 6nm zone and baselines (from the shore to the start of the 6nm zone) except for Precautionary Scientific Monitoring Quota to be agreed between ICES [International Council for the Exploration of the Sea]; Dept. of Agriculture and individual boat owners for 6nm zone only.

Minister for Agriculture, Food and the Marine, Martin Heydon T.D., and Minister of State with responsibility for Fisheries, Timmy Dooley T.D., agree a regime to sort out the complex issues involved in the contentious issue of fishing for forage fish by large sea-going pelagic trawlers inside Ireland's coastal waters (6nm) and Baselines (all of our bays, estuaries, harbours, and inlets).


"Forage fish are a keystone species. Their presence and abundance significantly impact the entire marine ecosystem. A decline in forage fish populations can have a cascading, negative effect on the entire marine environment."
[Forage Fish: Little Fish with a Big Impact (Pew)]

Newsflash: Coincidentally, almost a month to the day after this post and fictional "Headline" was written in June 2025, the Minister for Agriculture, Food and the Marine, Martin Heydon T.D., and the Minister of State with responsibility for Fisheries, Timmy Dooley T.D., announced a scheme banning trawlers over 18m LOA from fishing for sprat within the 6nm zone and baselines from October 2025 without authorisation and with a maximum TAC of 2,000 tons and a full ban from October 2026

Unfortunately, this ban on vessels over 18m LOA does not take into account the successful High Court action taken by fishermen against the previous ban, which was not appealed by the State to the Supreme Court, and it is therefore (obviously) an illegal ban, based on the previous High Court ruling and further ruling as affirmed by the Court of Appeal* (see notes at end of blog).

The latest announcement by the Minister for Agriculture, Food and the Marine, Martin Heydon T.D.; the Minister of State with responsibility for Fisheries, Timmy Dooley T.D.; supported by Minister of State  for Nature, Heritage, and Biodiversity, Christopher O'Sullivan T.D., is the same ban as the previous attempt at a ban on some boats (only) within the 6nm zone and baselines as the previously unsuccessful ban. It could be seen as a (very) cynical exercise by the Ministers concerned, to garner support from voters and constituents, in the full knowledge that it is an illegal ban, without the necessary legislation to support it.

Some environmental NGOs also supported this illegal ban, despite the wishes of the vast majority of their grassroots members for a total ban on fishing for forage fish within the baselines and 6nm zone, and not a selective and blatantly discriminatory one. If either the State Departments involved, or the environmental NGO's "top brass" involved, are looking for elementary but sound legal advice at half the price and twice the gain for the environment and protection of the marine biodiversity in our baselines and 6nm zone, please contact the writer of this article.

[A lot of the "top brass" in some of the environmental NGOs are getting a bit long in the tooth and a bit too long at the helm, and totally out of contact with the "lower rankings" and grassroots, like myself. They are also compromised by too much reliance on State and semi-State contracts and offshore oil-exploration and windfarm tenders for financial income (to support the high income earnings of their multiple "officers" and directors) and are no longer an appropriate medium for wildlife advocacy in Ireland.]


At the very least the fishermen concerned will have to be compensated (rightly) for loss of earnings.
The ban, as proposed, does not mention anything about vessels or TAC for vessels under 18m LOA fishing for forage fish within the 6nm zone and baselines, is non-specific and does not mention the various species of forage fish to be protected namely sprat, pilchards, anchovy, sardines and sand eels - all of which require protection within the baselines of our bays, estuaries, harbours and inlets and out to the start of the 6nm zone, as specified in Option 7 below. 

The first headline above is  a fictional headline  written on 23.06.2025 but it would be a very nice headline before the start of the 2025 sprat / pilchard / anchovy fishing season in September by large pelagic trawlers supported by BIM [Bord Iascaigh Mhara - Irish Sea Fisheries Board] for offshore trawling for herring, mackerel, horse mackerel, blue whiting and albacore tuna and not for destroying  the very base of the marine food chain by trawling within the baseline  in our bays, estuaries, harbours and inlets for spawning, keystone, forage fish species (sprat; pilchards; anchovy; sand eels) leaving our bays and estuaries as "Dead Zones" for other species of marine wildlife including commercial fish stocks, inshore commercial and recreational fishermen, cetaceans, pinnipeds and seabirds.

 

Who owns the sea? Who owns the fish? Who owns the commercial (quota) fish and the non-commercial (non-quota) fish? Who owns the marine resource? Whose responsibility is it to ensure  that we have a healthy, responsible, sustainable fishing industry from bottom to top and top to bottom? Who has superior rights, especially inshore -  Big Fishing  or the small inshore fisherman and the eco-marine tours industry (?) or have  the fishing vessels and the eco-marine tours vessels equal rights under the Constitution to our National marine resources (?)  especially in contested areas like within our baselines consisting of our bays, estuaries, harbours and inlets and out to the demarcation line for the 6nm zone? Have coastal communities any say in how the sea outside their front door is managed and protected as a sustainable resource for the common good of all? Have (some) fishers a superior right (Under the Constitution?) to this resource to the total detriment of other marine resource users like anglers; angling boats; traditional inshore fishermen; whale, dolphin and bird watching tour boats; divers; sailors; marine eco tour boats and many other users  because they have  bigger boats and bigger engines and bigger resources than the smaller insignificant inshore users of the same resource. This would definitely be a  case of discrimination on the grounds of pedigree (already proven in the Supreme court - Blascaod Mór Teoranta versus the Irish State )  if such a case for discrimination against specific  marine users was to be taken against the Irish State

Please continue reading for a general discussion of the (7) options towards a satisfactory solution to this conundrum for all parties. Please note that the author of this blog is not anti-fishing and supports the rights of fishermen to make a good living from the harsh environment in which they operate. I was a commercial fisherman for many years, pot-fishing for lobster and crabs and tangle-net fishing for crawfish, and dredging for native oysters in Fenit, Tralee Bay during the Autumn / Winter months. I was also engaged for many years in ferrying to An Blascaod Mór [Great Blasket Island ] from Dún Chaoin and presently in dolphin and whale watching tours  and marine wildlife charters from Ventry harbour. 

My grandmother and grandfather met on the high seas. on a Cunard liner from Liverpool  bound for Valparaiso, where my grandfather worked as a ship's officer (purser) and my grandmother was a rich lady's "travelling companion" (a job description rarely, if ever,  heard today and it may or may not have been a euphemism for "girlfriend" in those illiberal times). On their return from the voyage, they married and settled down in Ravensdale. over-looking Giles' Quay, Co.  Louth and my grandfather worked as a  marine pilot guiding ships to Dundalk port through the shifting sandbanks of Dundalk Bay.
I think that I have a broad view of the issues involved and hopefully show a pathway towards an environmentally sustainable solution that will benefit everyone involved in some way, but most importantly, protect the inshore marine ecosystems and marine biodiversity within the Baselines from the shore to the start of the 6nm zone.

Public Consultation on a Review of Trawling Activity Inside the 6nm Zone and Baselines

A  rather (legally) flawed consultation document was issued by the former Minister for Agriculture, Food and the Marine, Charlie Mc  Conalogue T.D. and the period for  submissions is now closed  and we are hopefully waiting for an headline as at the start  of this article!
Four options (only) were given, of which options 3 and 4 below, go against the High Court ruling previously successfully taken by two pelagic boat skippers over 18m and rightly so, and not appealed to the Supreme Court by the Irish State, and are therefore illegal and invalid options and can be contested in any court.

Option 1: "No change to the status quo"

This option is unacceptable, as a solution to a possible environmental crime must be found, otherwise the Irish State court be taken to the ECJ [European Court of Justice]  for not protecting the foraging resource for species listed as "qualifying  interest" in direct proximity to EU designated marine SACs [Special Areas of Conservation]. SPAs [Special Protected Areas (for birds)], and potential MPAs [Marine Protected Areas] and for not protecting the proximate foraging areas for cetaceans (like harbour porpoises), pinnipeds (like common and grey seals) and seabirds  (like Manx shearwaters, gannets and puffins) contrary to the EU Habitats Directive and the EU Birds Directive.

Option 2: "All sea-fishing boats excluded from pair-trawling inside the 6nm zone and baselines"

This sounds like the ultimate solution but fishermen would drive the proverbial "coach and four (horses)" through any legislation that only mentioned "pair-trawling", as vessels - especially large-powered fishing vessels - would merely adjust their gear to single trawling, even though it would be more expensive and less efficient. It also does not specifically mention any protection for forage fish like sprats, pilchards, anchovy, and sand eels.

Option 3: "All sea-fishing boats over 18m LOA [Length Over All]  excluded from trawling within the 6nm zone and baselines".

This option goes against the High Court ruling on discrimination which was not contested by the Irish State to the Supreme Court and is therefore an illegal option, or at best, such vessels would have to be compensated based on previous recorded landings of forage fish at properly designated ports.


Option 4: "All sea-fishing vessels over 15m LOA [length Over All] excluded from trawling inside the 6nm zone  and baselines.

Like the last option, this option is illegal based on precedent in the High Court, or the fishers affected would have to be compensated based on previous recorded landings of forage fish at properly designated ports.

Summary:

Of these 4 options given by the Minister, two are illegal, one is no change to the status quo, and Option 2 is the best option of these four, if the wording of the legislation is changed from "pair-trawling" to "trawling" or "fishing", and protection for forage fish is specified.

Further (3) Possible Options:

Option 5: "Precautionary quotas for forage fish allocated to individual boats by the Minister based on TAC [Total Allowable Catch] as recommended by ICES [ International Council for the Exploration of the Sea]."

At the present, forage fish including sprat, pilchards, anchovies, sand eels are non-quota and data-limited species  and have no legal protection, and there is nothing legally stopping fishing boats from hoovering up every last sprat from the shoreline - as is happening at the present - and thereby destroying the entire inshore marine ecosystem and the local inshore marine biodiversity.

If these forage fish were made a quota species, then at least they would have some protection and supervised regulation, based on ICES recommendations, until further scientific surveys could be completed both on their importance in maintaining a healthy marine ecosystem for other commercial fish, local inshore fishermen, marine tour operators, cetaceans (dolphins, whales and porpoises), pinnipeds (common and grey seals). and seabirds and to establish the sustainability or otherwise of the fishery with particular reference to "spawning and nursery areas, local stock structure and movements " [IWDG] especially in the near proximity to marine SACs, SPAs and soon to be designated MPAs.

Option 6: "Scientific Monitoring TAC only, for Forage Fish within the 6nm zone and excluding the baselines."

It is a constant mantra on both sides of the argument  that there is not enough data to prove either side right or wrong, with one side saying that they are doing nothing illegal in pair-trawling for forage fish, especially sprat and pilchards, right up to the shoreline, and the other side saying that it is blatantly obvious that forage fish are the base of the marine food chain, just superior in trophic value to sand eels and zooplankton, and that because of the damage to the marine environment and using the Precautionary Principle, the fishery should be stopped until there is proper scientific assessment made of stocks.
In their submission to the "Public Consultation on a Review of Trawling Activity inside the 6nm Zone" - "The KFO [Killybegs Fishermen's Organisation] acknowledges this fishery has remained largely unregulated over many years and there is an urgent need for a management plan to be put in place ....Management measures should be developed in consultation with the industry and take account of the socio-economic impacts on all stakeholders."

With both sides agreeing on the need for more scientific data to properly assess the sustainability or otherwise of the fishery and the importance of maintaining a healthy stock of forage fish, especially inshore and within the baselines to sustain a diverse marine environment and habitat, it seems that the best way to do this would be to allow a Scientific Monitoring TAC [Total Allowable Catch] only, within the 6nm zone excluding the baselines, with continuous monitoring of the stock for age, sex, spawning, body condition etc. This would involve the scientific community  and the fishing community working together side by side to properly asses the biomass and condition of the stock. Based on this data, and more scientific research required for the importance of a healthy forage fish population, especially inshore, for other commercial fish species and inshore fishermen under  10m LOA and angling boats, cetaceans, pinnipeds and seabirds, a sustainable future based on proper scientific data could be established.

Option 7: "No fishing for forage fish (sprat, pilchards, anchovy, sand eels) allowed within Ireland's baselines, from the shore to the inside start-line of the 6 nautical mile zone. All Baseline areas to be made MPAs to fulfill Ireland's obligations under the EU 2030 Biodiversity Strategy."

Most people, apart from fishermen, believe that the "six nautical mile zone" extends from the coast six miles out to sea following the contours of the land, but what seems obvious to most people is obviously untrue, as the "baseline" is a straight line drawn from headland to headland around the coast  and it also skirts the outer rocks and islands around the coast and this "baseline" area contains all of our  bays, estuaries, harbours and inlets.
Thus, large areas of our inshore waters are within the baselines which start at Malin Head to Melmore Head, Horn Head to Bloody Foreland to Arranmore Island to Gweebarra Bay to Rossan Point, Donegal Bay, Killala Bay, Blacksod Bay, Clew Bay, Galway Bay, Liscannor Bay, The Mouth of the Shannon  from Loop Head to Kerry Head, to Tralee Bay, Brandon Bay, Dingle Bay, St. Finian's Bay, Ballinskelligs Bay, Kenmare Bay, Bantry Bay, Dunmanus Bay, Roaringwater  Bay, and all inside a line from Toe Head to Galley Head to Seven Heads to Old Head of Kinsale to Ballycotton, Mine Head to Hook Head to the Saltees to Carnsore Point to Greenore Point to Rosslare Point. From Rosslare Point the baseline hugs the shoreline as far as Dundalk Bay which is also within the baseline from Dunany Point to Ballagan Point.
All of the waters within this line are referred to as  the "baselines" and the 6nm limit starts from this line 6nm out to sea and the 12nm limit starts from  the outer line of the 6nm line out to sea for another 6 miles. Those are our national inshore limits over which the Irish State has jurisdiction.

Fishing within these baselines is normally undertaken by smaller vessels under 10m LOA [Length Over All] and out to sea in the bigger baseline areas by vessels in the 10m - 15m LOA range by locally based fishermen, as  the bigger pelagic and demersal vessels are better equipped for offshore fishing for which they are designed. As herring and mackerel stocks have been over-exploited and in the case of mackerel have moved further north with climate change, and with strict quotas for herring and mackerel and further restrictions with Brexit, some pelagic boats which formerly targeted herring and mackerel are increasingly targeting the quick buck and the easy pickings inshore, within the baselines, of shoaling sprat and pilchards which come inshore during the late Summer / Autumn to spawn. 
This is so short-sighted and unsustainable and reminds me of someone wanting to cut timber and sitting on the wrong end of the branch (the outside of course!) while he saws away at the branch.

Not so many years ago the fish factory in Dingle had a conveyor belt system in place with rows of mainly female workers taking the "roe" (egg masses in sacs in female herrings) and the "pay" or "milts" (sperm sac from male herring) from the herring under  the supervision of a Japanese overseer and the product carefully packed in small cardboard boxes and flown directly to Tokyo and the herring discarded for offal, like the sprats and pilchards are today, for the fish-meal factory in Killybegs to be made into fish-meal pellets for salmon farms in Scotland and Norway. I did not think that it was  a good idea then, just like I do not think that it is a good idea today to fish the last remaining sprat and pilchards from our inshore bays and estuaries and when they are gone then perhaps target the next lowest trophic fish below them - sand eels - that convert the protein from the zooplankton that they eat into higher value commercial fish like cod, pollack, hake and haddock.

The rows of girls taking the roe and pay from the herring are gone, the herring are gone, the fish factory is gone and is now a museum and theatre and restaurant. Surely, we can learn a lesson from the past.

Based on all of the above, Option 7 is the option that I would choose as the best option, as inside the baselines areas listed above are the nursery areas, including sandy bottoms, gravelly bottoms, muddy bottoms and eelgrass meadows for most of our commercial fish stocks  and the most important area for our inshore biodiversity including dolphins, whales, harbour porpoises, seals and seabirds.
Only a very limited Scientific Monitoring TAC should be allowed within these baseline areas [e.g. 2,000 tons by the local inshore fleet] and of particular interest would be a study of the site fidelity of various forage fish species (including sand eels who are reputed to have a "home range" of approx. 20 miles) to specific local areas, as there is scientific and anecdotal evidence that many of these schooling forage fish are site specific to local areas and if the adults are wiped out the juveniles of the next generation are unable to relocate the traditional spawning grounds.

Discrimination against Marine Tourism Operators, Inshore Fishermen, Angling Boats, Diving Boats. Dolphin and Whale Watching Boats, Pelagic Bird Watching Boats, Marine Eco Tour Operators, in Public Consultation Document issued by the Minister for Agriculture, Food and the Marine on "A Review of Trawling Activity Inside the 6nm Zone and Baselines."

The consultation document is supported with various academic and scientific papers supplied by:

Dept. of Agriculture, Food and the Marine: "Consultation paper on Minister's Review of Trawling Activity inside the 6nm Zone."

Marine Institute: "Fisheries inside Ireland's 6nm Zone" [2018 - 2022]

BIM [Bord Iascaigh Mhara - Irish Sea Fisheries Board]: "Economic Assessment of Fishing Activity within Ireland's 6nm Zone." [2018 -2022]

There is no information paper from the NPWS [National Parks and Wildlife Service] setting out the effects of continued fishing for forage fish within the 6nm zone and baselines, many of which are in close proximity to EU designated marine SACs for EU Habitats Directive protection and SPAs for EU Birds Directive protection and in areas overlapping proposed MPAs. These areas include Blasket Islands SAC; Roaringwater Bay and Islands SAC; and Lower River Shannon SAC and the surrounding foraging sea areas for harbour porpoises; grey seals; common seals; dolphins including common, bottlenose and Risso's dolphins; and whales including Minke, Fin and Humpback whales; breeding seabirds including puffins, Manx shearwaters, Storm petrels, kittiwakes, gannets, razorbills, black guillemots, common guillemots, herring gulls. lesser black-backed gulls and great black-backed gulls and for commercial fish stocks of higher trophic value.

There is no paper by the NPWS setting out the ecological value of these forage fish supporting the base of the marine food chain, just above sand eels and zooplankton in the trophic level and the effect that taking this keystone species out of the marine food web has on EU protected habitats and species and may be one of the primary causes of creating "Dead Zones" within the baselines in our bays, estuaries, harbours and inlets as listed above.

The omission by the Minister for Agriculture, Food and the Marine to supply any information whatsoever by the relevant government authority - NPWS - of the effects of continued trawling for forage fish within the 6nm zone and inside the baselines - which some may view as an environmental crime - on the whole marine biodiversity of our national bays, estuaries, harbours and inlets, lead this whole Public Consultation process open to Judicial Review. 


The Whole Irish Marine Ecotourism Fleet Discriminated against by Negligent Omission in Favour of a Small Minority of Large Pelagic Trawlers destroying the Marine Ecosystem within the Baselines of our National Bays, Estuaries, Harbours and Inlets.

Whereas, BIM includes a paper entitled "Economic Assessment of Fishing Activity within Ireland's 6nm Zone" with the Public Consultation Document on a "Review of Trawling Activity inside the 6nm Zone and Baselines", there is no reference whatsoever, or no specific paper by BIM on:
"Economic Assessment of Marine Tourism Activity within Ireland's 6nm Zone and Baselines."
This is despite the fact that BIM have spent up to 40 million recently in grant-aiding the sector, and have been grant-aiding the sector since 1994 when they first introduced grants for fishermen to diversify from the  fishing sector and sell off their tonnage, as did the author of this blog.

In this "consultation document" the rights of the whole tourism operators fleet have been totally ignored, even though the earnings of this fleet are presently a multiple of the earnings from the "sprat" fishery element of the small number of pelagic trawlers engaged in "sprat fishing" (including pilchards, anchovy, sardines and potentially sand eels) and the socio-economic benefits of marine tourism to the local communities are a multiple of that again, in bringing high-spending tourists to local coastal ports, towns and villages, decimated  by the downturn in the fishing industry since Ireland joined the EU; the ban on drift-netting for salmon; Brexit; poor quotas and depletion of inshore stocks.

Marine Tourism: Real Local Data:

Twenty marine tourism boats [ 13 X 12 pax. boats and 7 X Class VI (over 12 pax. and under 100 pax.)] operate from the Dingle / Ventry/  Dún Chaoin area alone, giving employment to 50 people during the 7 months tourist season and 15 permanent jobs, with an annual gross income of approx. €4 million. Using the 3:1 ratio for extra money spent by each tourist (including Irish tourists)  for every €1 spend on boat trips, that brings in approx. €12 million to the local economy and community spent on food, drink, transport, restaurants, cafes, shops, accommodation, hotels, B and Bs, Airbnb, pubs, cultural events and venues, other local activities and attractions.

Compare this to a pair of transient ( 5 to 6 weeks) pelagic trawlers fishing for "sprat" (pilchards, anchovy and potentially sand eels) in Dingle Bay and surrounding waters until the spawning forage fish shoals are depleted, and the economic and monetary return from this activity transporting forage fish to the offal and fish-meal factory in Killybegs is negligible by comparison, and the socio-economic return to the local community is almost nil, and these pelagic trawlers are not relying on this "sprat" fishing in order to remain viable but instead rely on their lucrative herring, mackerel, horse mackerel, blue whiting and albacore tuna fishing quotas. Total gross income from circa 17,000 tons of sprat / pilchards @ €150 per ton equals €2.5 million.

This example from Dingle Bay of the monetary, economic and socio-economic benefits to the local coastal community of the marine tourism fleet within the baselines (our bays, estuaries, harbours and inlets) in comparison to depleting the forage fish stocks on which this eco-tourism product is based, can be replicated along the SW and S coast, and along the W coast and up to Donegal Bay where humpback whales are now making a more regular appearance and a matching marine eco-tourism fleet is developing.

It is entirely unacceptable that as well as not having a paper from the NPWS on the effects of trawling for forage fish within the 6nm zone and baselines on the marine ecology and potential harmful effects on EU designated SACs and SPAs and the potential harmful effects on cetaceans like harbour porpoises, pinnipeds like grey and common seals and breeding seabird populations like Manx shearwaters and gannets, contrary to the EU Habitats and Birds Directives, there is also no accompanying paper from BIM on the potential harmful effects the continued fishing for forage fish, especially within the baselines of our bays, estuaries, harbours and inlets would have on the marine tourism sector and fleet contrary to the MSFD [Marine Strategy Framework Directive] and the NMPF [National Marine Planning Framework].

Because of these omissions from the "Public Consultation on a Review of Trawling Activity inside the 6nm Zone and Baselines" there would be substantial grounds for a Judicial review and a case for discrimination based on pedigree / marine usage for marine tour operators vis fishing rights, especially within the baselines of our bays, estuaries, harbours and inlets, if either Option 1 - "No change to the status quo" - or trawling for forage fish is allowed within the baselines, and anything other than a scientific monitoring TAC is allowed within the 6nm zone and excluding the baselines.

                                           Summary:

1. No fishing for any species of forage fish (sprat, pilchards, anchovy, sand eels ) by any fishing vessels to be allowed within the baselines mentioned above in Option 7.

2. No fishing for any species of forage fish within the 6nm zone except for Scientific Monitoring TAC [maximum 2,000 tons] by local inshore fleet, to be agreed with ICES.

3. All of the already existing and clearly demarcated Baselines mentioned above in Option 7 - which are separate to the 6nm fishing zone - to be nominated as MPAs, to fulfil Ireland's commitments to protect 30% of its marine territory by 2030 under the EU 2030 Biodiversity Strategy.

4. Local inshore fishermen, commercial and recreational (angling boats), and other local marine resource users to be directly involved in "bottom up" management approach of each baseline MPA with sustainability of the local inshore-fleet fishing effort, and maintaining a rich inshore marine biodiversity the main criteria.

5. Any fishermen or fishing company, at a financial loss due to the proposed ban on fishing vessels fishing for forage fish within the 6nm zone and baselines, to be adequately compensated by the State based on previous recorded landings of forage fish at properly designated ports.

6. Let's stop talking about "sprat" and instead focus on protecting all forage fish (sprat / pilchards / sardines / anchovies / sand eels) within our baselines (especially) and 6nm fishing zone.

                                                                Important Notice:

This is not an anti-fishing article, and the author is not in the anti-fishing camp, and is firmly embedded in supporting our hard-pressed fishermen.

No bona fide fisherman [ or farmer for that matter] should be at a financial loss for supporting environmental and biodiversity initiatives and if the present Option 7 proposal was to be introduced, it would require a parallel mechanism for compensating those bona fide fishermen presently engaged in the "sprat fishery" (also pilchards, anchovy and potentially sand eels) based on previously recorded landings at the properly designated ports.

Total landings of sprat / pilchards in Irish waters for 2024 were reported to be in the region of 17,000 tons @ approx. €150 per / ton which would be worth a little over €2.5 million, with the SFPA  figures showing 7,000 tons of the 2024 sprat / pilchard catch went to boats over 18m LOA @ approx. €150 per / ton which would be worth a little over €1 million. [It is uncertain how accurate these figures are, or whether the SFPA inspects / records properly the landings of non-quota forage fish species at Irish ports, as a request for information under the FOI Act by the author was denied under a technicality.]

This would be a small price to pay for the recovery of the marine biodiversity, including recovery in commercial fish stocks, for the inshore commercial and recreational fisherman, in our inshore waters within the baselines, consisting of our bays, estuaries, inlets and harbours, like Ventry Harbour.

The fisherman and the conservationist could work together for the mutual benefit of both, and for the benefit of the common good and the marine environment, and its various inhabitants and users, including fish, dolphins, whales, porpoises, seals and seabirds and for the many and varied users of our wonderful, inshore marine resource.

Mick Sheeran                           25.06.2025z

Log of the Whale Watching Tour Boat M.V. "Blasket Princess"


Notes:

*Legal background to previous 6nm and baselines ban on vessels over 18m LOA  [Without Prejudice]

1. Policy Directive 01 of 2019 signed by Minister for Agriculture in March 2019 to come into effect on 01 January, 2020 banning vessels over 18m from trawling for forage fish within the 6nm zone and baselines.
2. May, 2019 Judicial Review application to High Court by fishermen affected by the ban
3. October 2020. The applicants were successful in their application to the High Court
4. November, 2020. The Minister for Agriculture  lodged an appeal
5. March 2021. Court of Appeal gave a temporary stay on the Order of the High Court and there was a re-instatement of the ban.
6. June 2022.. Court of Appeal extended the stay on the temporary stay of the Order.
7. September 2023. The Court of Appeal refused the Minister for Agriculture's application to continue the stay on the High Court order and Policy Directive 01 of 2019 was pronounced invalid.
8. There was no further appeal by the State to the Supreme Court
9. This legal quagmire and saga to be continued............................

*Pelagic:
1. "Of or relating to the open sea" 
2. "(of marine life) living or occurring in the open waters of the open sea" - Collins English Dictionary

**Forage Fish of the NE Atlantic:
Sprats: (Sprattus sprattus) - marketed as "brisling sardines."
Pilchards: (Sardina pilchardus)  -"true sardines"
Sardines: (Sardina pilchardus)
Anchovy: (Engraulis encrasicolus)
Lesser sand eels: (Ammodytes tobianus), (Ammodytes marinus.)
Greater sand eels: (Hyperoplus lanceolatus) 

Forage Fish of the NW Atlantic:
Capelin: (Mallotus villosus) Found around Iceland; Western Greenland; off Newfoundland and Labrador; Hudson Bay to Maine
Menhaden: (Brevoortia tyrannus) - sometimes referred to as "the most important fish in the sea" - Found in coastal and estuarine waters (like our sprats / pilchards)  from Nova Scotia to northern Florida.

***TAC
Total Allowable Catch of a species annually, determined by EU Council of Fisheries Ministers based on scientific advice from ICES


ICES
International Council for the Exploration of the Sea

Quota:
Based on the recommended TAC, the Minister for Agriculture, Food and the Marine allocates a monthly quota to individual fishing companies and boats.