22 AUGUST 2017




Protests have been lodged by environmental and animal rights groups against an alleged ‘journey from hell’ for fish raised on a salmon farm off the Irish coast.


The fish were previously transported to the local town for slaughtering before being dispatched to the market. However, last month the company involved, Marine Harvest, changed their slaughtering from Castletownbere where the farm is located to their headquarters in Rinmore, Donegal, a distance of 640 kilometres.


According to local activists, the fish are now being brought to a small local pier, recently extended by the company, and piped into stainless steel tankers for the journey to the slaughterhouse at the other end of Ireland. ‘It is almost unimaginable what it must be life for these fish to be jammed into a tanker across Irish roads for more than 600 kilometres.’


This operation is certified by the Aquaculture Stewardship Council on the basis of the fish being harvested locally. The product has ‘organic’ status.


Friends of the Irish Environment [FIE], who have offices in the area, have coordinated complains to the authorities, including the Minister for Agriculture [1], who licenses fish farm operations. The Department’s Aquaculture Division has asked the Departments Marine Engineering Division and the Marine Institute to investigate the matter. The ISPCA Irish Society for the Prevention of Cruelty to Animals has also contacted the Minister for Agriculture about the operations.


According to FIE, the operations have been continuing for more than a month, including Sundays and holidays, and have been the subject of ‘almost daily’ complaints to their offices over noise, danger to traffic, and disruption, with callers citing disturbance to the local seal and otter populations. The area is designated for protection under the Habitats Directive but the relevant Minister, Heather Humphries, has declined to intervene and referred the matter back to the Minister for Agriculture.


Fie Director Tony Lowes said that on road safety grounds alone the narrow twisting local road ‘was restricted to 3 tons. The unloaded weight of the tankers exceeds that limit alone. The area is totally unsuitable for this kind of operation.’


The farm is licenced to hold 5,000 tons of fish which, according to their website, are currently being harvested. [2]

Further information: Tony Lowes 087 2176316 / 353 (0)27 74771




[1] Letter to Minister of Agriculture of 4 August, 2017





Environmental group reacts to court ruling that grants Ryanair leave to participate in runway challenge


The High Court today allowed Ryanair to participate in a legal challenge being taken by Friends of the Irish Environment against Fingal County Council's decision to extend the permission granted in 2007 for a third runway at Dublin Airport. Ryanair, which originally opposed the third runway, now supports it and came to court claiming it had a financial interest in the runway going ahead.


FIE Director Tony Lowes commented: "We are deeply concerned that Ryanair, a company which denies the existence of climate change has now been accepted as a party to these proceedings. We are concerned that the court’s decision will skew the proceedings away from the environmental impacts of aviation towards commercial considerations.


Climate change is real. Irish and international law commit us to reducing emissions. Unconstrained growth in aviation as foreseen by the Dublin Airport Authority is not compatible with those legal obligations."


Across the world, climate debates are increasingly ending up in the courts in situations where national policy is not being implemented on the ground. In Austria, a federal court blocked the expansion of Vienna’s international airport because the increase in carbon emissions that a new runway would generate was deemed to be inconsistent with the country’s commitments to tackle climate change. In that case, the court decided that the public interest was best met by restricting growth in emissions rather than allowing airport expansion.


FIE is particularly concerned that Ryanair – a highly successful airline built on the Low-Cost Carrier model (LCC) – has a reputation for dismissing climate science. Michael O Leary has recently claimed that climate change is ‘complete and utter rubbish’, and that he does not accept that climate change ‘is real’. According to FIE director Tony Lowes, “these remarks suggest that the airline has no regard for science-based policy or indeed, the public interest. Ryanair is hiding its powerful commercial interests behind denial because it has no other argument left.”


FIE, which was founded in 1997, is represented FP Logue Solicitors and John Kenny, BL.


SPOKESPERSON: Sadhbh O’Neill    353 (0)87 2258599

Verification, documentation, and to arrange Irish language spokesperson

 Tony Lowes  353 (0)87 2176316




The International Civil Aviation Organisation (ICAO) estimates


The recent decision of the Austrian Federal Administrative Court to refuse permission for a 3rd runway at Vienna Airport due to the negative impact of climate change and the contribution to it by air traffic:

Unofficial translation into English:


Background to the case being taken by FIE

Friends of the Irish Environment is seeking a Judicial Review of the decision of Fingal County Council to extend the 10 year period granted to Dublin Airport Authority to construct a third runway at Dublin Airport due to the increased greenhouse gas emissions resulting from ongoing aviation growth. FIE says this decision is contrary to the Climate Action and Low Carbon Development Act as well as The Irish Constitution and international agreements to tackle climate change.




A Judicial Review brought by Friends of the Irish Environment (FIE) alleges that the Chief Executive of Fingal County Council failed to provide satisfactory explanatory reasons for granting the extension to the original decision to allow a third runway at Dublin Airport. FIE alleges that the record shows that the Chief Executive was fully aware that the extra runway would result in increased greenhouse gas emissions, in contravention of the objectives of the 2015 Climate Action and Low Carbon Development Act. 


Globally, aviation currently is responsible for about 5% of anthropogenic radiative forcing or human-generated climate change. However, while emissions from some countries and economic sectors are falling, emissions from international aviation are growing at over twice the rate of overall emissions. The International Civil Aviation Organisation (ICAO) estimates that, if the current trends continue, aviation emissions will increase by up to 300% by 2050, the period over which overall global emissions must be massively reduced if we are to meet the targets set in the Paris Agreement.


The planned third runway at Dublin Airport is based on the scenario of unconstrained aviation growth and travel demand which is incompatible with the Paris Agreement.  It reflects an implicit assumption by the Dublin Airport Authority (DAA), Fingal County Council and the Irish Government that no steps will be taken to limit the growth in aviation. Effectively the proposal assumes that we will ignore, or not bother trying to meet, the targets in the Paris Agreement.


According to FIE  Director Tony Lowes’ affidavit, the Fingal Chief Executive confined his consideration to a number of 'entirely general observations in relation to the International Civil Aviation Organisation and the possibility of certain actions being taken by the European Union in 2017 and 2018. These observations do not discharge the Council’s obligations under the legislation to have regard to four criteria – the national mitigation plan, the national adaptation framework, the implementation of the national transition objective, and the objective of mitigating greenhouse gas emissions - before deciding to grant the extension.


In this case, the Chief Executive made no mention of these legal requirements. "The fact is that the international and national context in respect of climate change has moved on dramatically since the runway was first granted permission, which included a very limited assessment of climate impacts. Every citizen possesses constitutional and natural rights to bodily integrity, life, water, food, health and an environment consistent with their right to dignity and well-being. Climate change will directly and irrevocably impinge on each and all of those constitutional and natural rights", according to the organisation’s challenge.


FIE has drawn attention to the recent decision of the Austrian Federal Administrative Court to refuse permission for a third runway at Vienna Airport due to the negative impact of climate change and the contribution to it by air traffic.


Further, in granting an extension in time to a permission given in 2007 on the basis of a 2002 Environmental Impact Statement, the Council has failed to consider any of the body of recent research, including IPCC Reports, for the last 15 years. FIE further contend that the grant of an extension of time for the runway, ten years after it was first granted and without any public consultation, is contrary to EU law.


FIE, which was founded in 1997, is represented FP Logue Solicitors and John Kenny, BL.


SPOKESPERSON: Sadhbh O’Neill    353 (0)87 2258599

Verification, documentation, and to arrange Irish language spokesperson

 Tony Lowes  353 (0)87 2176316




The International Civil Aviation Organisation (ICAO) estimates


The recent decision of the Austrian Federal Administrative Court to refuse permission for a 3rd runway at Vienna Airport due to the negative impact of climate change and the contribution to it by air traffic:

Unofficial translation into English: 

Minister Dennis Naughton, TD, Minister for Communications, Climate Action and Environment, has been urged to support a United Nations Convention’s ruling requiring suspension of work on the new Hinkley Point UK nuclear reactor until a transboundary Environmental Impact Assessment [EIA] is completed.


The first new nuclear station to be constructed in the UK since 1995, Hinkley C is a 3.2GW nuclear power plant composed of two reactors. The power plant will generate 7% of UK's electricity if constructed. The UK position is that “the likely impacts determined through a thorough EIA do not extend beyond the county of Somerset and the Severn Estuary”.


The Espoo Convention, signed by Ireland in 1991, requires that the opportunity for comment provided to the public of potentially affected Parties is ‘equivalent to that provided to the public of the Party of origin’.


A complaint from the Irish NGO Friends of the Irish Environment in March 2013 to the UN Economic and Social Council determined that the UK did not met its obligations under the Espoo Convention.


The finding are due to be confirmed by a Meeting of the Parties to the Convention in Minsk on 13 June. FIE cited Ireland’s failure to answer the Committee's direct question about transboundary impacts when it was investigating this matter, writing ‘it is essential that you take a personal interest’.


FIE’s complaint cited an Irish Radiological Institute Report which acknowledged that in the event of an accident, Irish agriculture could be affected. ‘Food controls and agricultural protective measures would be required if any of these accidents occurred to ensure that food on sale in Ireland was safe to eat. In the case of the most severe accident scenario examined in the study, short-term measures such as sheltering would also be required’, the IRI Report concluded.


A spokesman for the group sad that ‘In spite of a strongly anti-nuclear Irish public, the Irish civil service decided that Ireland should bury it's head in the sand on UK nuclear issues for the sake of overall Anglo-Irish relations. The issue is far wider than simply Ireland and the UK. The current Minister must accept responsibilities under a Convention which we signed many years ago, represent Ireland’s long-standing opposition to nuclear power, and support international law under the United Nations ruling’.


The groups letter concludes: ‘We believe your support for the rulings of the Committee would be consistent with your own concerns for nuclear safety and effective international environmental law’.



Contact: Tony Lowes 027 74771 / 087 2176316


Letter to the Minister

For details see previous FIE press release and related documents:


Irish Radiological study


The Espoo Convention is about Transboundary Environmental Impact Assessment and has taken on a particular importance in relation to nuclear power issues.  

FIE has also urged the Minister to support a German initiative to amendment to the EIA legislation to require an assessment for renewal of licenses for nuclear power plants which are already old and dilapidated today. The move follows the upholding of a complaint to the Espoo Committee by a Ukraine NGO which has resulted in the Ukraine’s offer to subject the renewal of the licence for its nuclear plant at Belarus to a transboundary EIA.

FIE has told the Minister that ‘Involvement in a transboundary EIA prior to lifetime extensions is a valuable instrument for governments and the public to raise concerns and discuss particularly severe problems.’

FIE is in contact with NGOs in other European countries in relation to other Espoo Convention issues, whose concerns have informed our requests to Minister Naughten in relation to the issue of EIA for time extensions for nuclear plants reaching the end of their original design lives and in relation to the lack of EIA for a new nuclear plant in Belarus.




18 March 2017

Work at the UK’s proposed Hinkley Point C nuclear plant is under threat after investigation of a complaint to a UN Committee by the Irish environmental group Friends of the Irish Environment and a German Member of the Bunderstag German MP Sylvia Kotting-Uhl.


Following the UK Government's decision to approve the Hinkley Point C power plant without consulting the affected public in Ireland and other European Countries, FIE complained to the United Nations Implementation Committee of the Espoo Convention on Environmental Impact Assessment in a Transboundary Context in March 2013 that we in Ireland had been deprived of our right to be consulted by the UK before constructing the first of a new series of nuclear power plants


The UN Espoo Convention, signed in the Finish city of Espoo in 1991, requires that the Party of origin ‘shall ensure that the opportunity provided to the public of the affected Party is equivalent to that provided to the public of the Party of origin.’ Ireland is signature to the Convention.


No such consultation took place before construction began on the UK nuclear plant. The Committee up held the complaints and ruled in June 2016 that the UK Government had failed to ensure that citizens of neighbouring countries had an equal right to be consulted about the proposed nuclear plant.


The Committee recommended that the United Kingdom contact neighboring governments to determine if they wished to be consulted as part of a transboundary EIA procedure. The Committee also decided to recommend to the Meeting of the Parties that if a potentially affected Party requests to be notified, the United Kingdom should suspend works related to the proposed activity until the transboundary EIA procedure is finalized.


According to information obtained by Sylvia Kotting-Uhl, the UK accordingly wrote to neighbouring countries 21 December, 2016. The MP confirmed that three countries – Germany, Norway, and the Netherlands - had responded seeking such a procedure, triggering the request to suspend work.


Ireland’s position from 2013  is that since the United Kingdom had concluded the likely impacts determined through a thorough EIA do not extend beyond the county of Somerset and the Severn Estuary’ that the requirements under the Convention regarding notification to other States did not arise and formal notification was not necessary.


Citing the Radiological Protection Institute of Ireland [RPII] report and the subsequent ESRI 2016 study on "The potential economic impact of a nuclear accident - An Irish case study", FIE has written to Minister Naughten asking him what response Ireland made to the 21 December 2016 letter from the UK.


In its letter to the Minister, FIE drew attention to the UK’s decision of January 2017 to withdraw from the Euratom Treaty and sought reassurances ‘that policy changes have been made since 2013 to support the right of Irish citizens to partake in trans-boundary decisions.


‘The current Japanese liability for the continuing Fukushima Daiichi nuclear disaster stands as a stark warning against those, like the Irish Government, who accept the UK arguments that trans-boundary risks are so small as not to require assessment. Despite this, the Irish Department of the Environment and successive Ministers have sought to wash their hands of this matter. It is now up to Minister Naughten to stand up for public safety and to assert the rights of Irish citizens to participate in a transboundary Environmental Impact Assessment.’



Comments: FIE Tony Lowes 087 2176316


Sylvia Kotting-Uhl MP, Spokesperson on nuclear policy issues, Parliametary group Alliance 90/The Greens Tel +49 30 227 747 42


Letter to the Minister

Radiological Protection Institute of Ireland outlined the risks to Ireland

Espoo May 2016 Report

Espoo March 2017 Report

The Austrian Federal Environmental Agency Expert Statement