We are very concerned about the recent expansion of canoeing activities on the Lower River Shannon SAC, and other Natura 2000 rivers such as the River Suir. The numbers of canoes and kayaks on the Lower Shannon and elsewhere has increased dramatically over the last decade, without any assessment, plan or regulation. This expansion is likely to continue and requires an urgent review. We are not against canoeing – and canoesists, anglers and environmentalists have much common ground and shared interests – but this sport has to be developed in a sustainable manner. The recent development of a major salaom canoeing course in the Lower River Suir SAC in Clonmel without Appropriate Assessment (see below) has added to these concerns. Similarly the clearance of priority alluvial forest within the Lower River Shannon SAC to provide access for a rowing club is totally unacceptable (also discussed below).

Canoeing has the potential to have a number of ecological impacts. The potential disturbance of spawning Atlantic Salmon and Sea Lampreys is one. The Lower River Shannon is a designated Special Area of Conservation for both of these species, and both are at unfavorable conservation status. Therefore any impact on these fish species must be considered to be ‘Significant’.

It is very easy to disturb salmon whilst they are spawning which can cause the female to abandon the redd before covering the ova – with severe consequences. Similarly Sea Lampreys can easily be disturbed and will abandon their nests if disturbed at critical times. On the Lower River Shannon commercial companies are now bringing large groups of canoes though the Castleconnell beats on a regular basis – throughout both the salmon and lamprey spawning seasons. Groups of people in garish canoes paddling and passing over fish when they are spawning will disturb them. Walking instream and pushing paddles & canoes over gravels may also physically disturb redds. Due to their small size canoes can access shallow areas which are inaccessible by other watercraft. Canoeing is also usually undertaken by groups of people – rather than individuals – adding to the potential disturbance.

Canoes are also coming and going from other river catchments (and other countries) with the very high risk of importing and dispersing non-native species and diseases (i.e. crayfish plague). There is no evidence that appropriate bio-security measures are actually followed on the ground. Due to the immersive nature of canoeing this activity poses a very high risk of transferring non-native species/diseases – if suitable precautions are not taken.

We need to have an urgent discussion about the development of canoeing on our Natura 2000 rivers. Commercial companies will have to be made comply with the requirements of the Habitats Directive and prepare plans, environmental codes of practice, and Natura Impact Statements as necessary. Canoeist numbers may need to be controlled and limited to certain numbers, areas, and times. Angler’s have to pay a licence and day ticket to fish and there is a daily rod limit – why has it become a free-for-all for canoeists? The canoeing community, anglers and conservationists have much common ground and shared interests. Addressing current issues is essential however to avoid emerging conflicts. It is noted that there has been little scientific research on the ecological impact of canoeing. The only study that seems to be available is an Environment Agency (2000) report entitled “The Effects of Canoeing on fish stocks and angling”. This report assessed the conflict between anglers and canoeists however, rather than assessing impacts on the actual fish themselves. Moreover, this was research on attitudes and was undertaken using questionnaires and did not include any environmental research. The report is also out-of-date and focused on angling species only and did not discuss lampreys, for example. Moreover, the issue of spreading non-native species and diseases was not explored in any detail. It is noteworthy however that the majority of respondents to the questionnaire issued in this study believed that canoeing could impact upon fish stocks by disturbing spawning gravel/redds. Some respondents stated that canoeing does impact upon fish stocks by disturbing spawning gravel/redds. It is noted that the precautionary principle must be applied on Natura 2000 rivers and if research is absent then it must be assumed that the effects are potentially significant. Lessons for Lower River Shannon : Major slalom canoeing course constructed in Clonmel breaches Habitats Directive

A major slalom canoeing course was constructed in the Lower River Suir SAC in Clonmel last year. However, no Appropriate Assessment (AA) was completed by Tipperary County Council/ Canoeing Ireland for this development, or indeed for the overall Suir Blueway Project. Appropriate Assessment is a legal requirement for projects with the potential for significant adverse effects on a Natura 2000 site. A Screening for Appropriate Assessment report was prepared for this development by the council themselves – but this incorrectly ruled out any potential for significant adverse effects on the SAC (or a requirement for any mitigation). No supporting species-specific ecological surveys were undertaken to inform the assessment. Moreover, the “Screening Report” did not comply with national and European guidelines for such assessments. By avoiding AA the council award planning permission for this major development to themselves. A project like this requiring significant instream construction works within a Natura 2000 river – and ongoing disturbance and biosecurity risk from the operational slalom course – could never be screened out from the requirement of Appropriate Assessment. The assessment should have identified that the instream works were a clear physical threat to juvenile lampreys which lived in the river bed along this stretch. These works also posed a risk to water quality, and would have the potential to disturb otters. It should also have been identified in advance that a slalom course would result in ongoing disturbance in within the SAC with the potential to disturb migratory lampreys spawning, and otters. Salmon would also be affected by disturbance of their spawning sites – and many events have already taken place during the winter months. A major event is now planned for lamprey spawning season in the spring of 2017. Because the weirs at Clonmel block the migration of lampreys, the area where the slalom course was developed is a key spawning site for lampreys in the lower Suir – with Sea Lampreys at unfavourable conservation status and at risk of being lost from this catchment. The major biosecurity risk which both construction and operational phases of this project posed should have been identified in advance. All of these impacts have the potential to be significant and required mitigation, and this should have triggered an AA. However, you also have to ask should a slalom canoeing course even be considered for a Natura 2000 river? This project will now be the subject of a complaint to the European Commission. The commercial development of the Castleconnell beats as an informal slalom course is also similarly of concern. The numbers of canoes and kayaks here has increased dramatically over the last decade, without any assessment, plan or regulation. This expansion is likely to continue and requires an urgent review. The Shannon Rowing Club development Another example of unsustainable activities of paddle sport groups is the development of the Shannon Rowing Club access in the Lower River Shannon SAC. This site is also used by canoeing clubs to access the river and has hosted events apparently managed by Canoeing Ireland. This development is another clear breach of the requirements of the Habitats Directive where there was industrial scale type development and encroachment onto the riparian area of the Lower River Shannon SAC. This has caused loss of over 500 m2 of priority Alluvial forest 91E0 habitat within this Natura 2000 site. Again this will be the subject of a complaint to the European Commission. The clearance of this woodland habitat within the SAC took place during the bird nesting season. It is noted that planning permission for these works were granted by Limerick County Council even though it had been identified in advance that priority woodland within the SAC was to be removed. In this case, and in relation to the Clonmel development discussed above, the main fault lies with the local authorities.

Obviously canoeing is not the biggest threat to the ecology of the Lower River Shannon, with water pollution and hydroelectricity regulation clearly the key pressures. Angling also has an impact and can cause disturbance to spawning lampreys while wading (e.g. the crossing point anglers use at beat 6). Moreover, the biosecurity issue also needs further promotion within the angling community. However, there is no angling during the salmon spawning season and most angling is done from the bank and margins of the river on the Lower Shannon. Angling is also a quiet, generally solitary, sport and is both regulated and licensed.