COAST OBJECT TO MARINE HARVESTS PROPOSED NEW FISH FARM AT CLAUCHLANDS.

COAST HAVE SENT OBJECTIONS to North Ayrshire Council, The Crown Estates S.N.H. and S.E.P.A. regarding Marine Harvests intentions to site one of the largest fish farms in Scotland off Clauchlands point.

FEED SILO AT EXISTING LAMLASH SITE

COAST’s objections are initially based on the 9 points below.  We believe as an island and islanders, who value their natural environment so highly, that to grant permission for a floating industrial unit of this size will damage not only our environment but also our economy.  The natural beauty of the island is the fundamental basis of its economy through tourism.

Marine Harvest a Norwegian owned company listed by the Scottish environmental protection agencies as one of the top ten polluters in Scotland.  At the public meeting on the island on the 20th December, not one of the 8 members of their management could find any benefits to the island other than 4 new jobs.

 Proposed Fish Farm. Application No. XX100/224. Clauchlands, Isle of Arran.

1.   The Environment Statement
2.      The effect on the COAST project
3.      The landscape and visual impact of the area
4.      The North Ayrshire Local Plan
5.      The effect on wildlife in the area
6.      The net benefits to Arran
7.      The effect of fish escapes from the Fish Farm
8.      The effect of the effluent and chemicals from the Fish Farm
9.      Marine Harvest’s record in Scotland and at the St Molios site, Lamlash Bay

1. The Environment Statement for the fish farm at Clauchlands is fundamentally flawed. It has been prepared by Marine Harvest itself, the only people who will benefit from its implementation and as such can hardly be seen as being unbiased. An independent assessment of the Marine Harvest submission should be carried out by a transparently independent consultant agreed in collaboration with all parties involved and affected by this proposal. These should include the Community of Arran, Community of Arran Seabed Trust [COAST], The Clyde Fishermen’s Association, Scottish Natural Heritage, Scottish Executive Environmental and Rural Affairs Department, local marine scientists and the Environment and Rural Development Committee of the Scottish Parliament, who are all recommending COAST’s project.
2. The proposed fish farm site directly conflicts with COAST’s project which calls for a No Take Zone and Marine Protected Area in Lamlash Bay and a Scallop Reseeding Area around the Bay, which when established will be Scotland’s first such highly protected marine reserve. The positioning of a fish farm abutting the trial area will cause great offence to many local people, who have campaigned for protection of the seabed around Arran. COAST, with the assistance of the Scottish Parliament’s Environment & Rural Development Committee, SEERAD, SNH and commercial fishermen support a scheme that brings this highly protected marine reserve to fruition and for perhaps the first time, has commercial fishermen working together with a community organisation on a mutually benefiting project. Locating this fish farm on the proposed site could put the whole project in jeopardy.
3. The very large fish farm proposed will have a considerable impact on the visual aspect of this beautiful scenic area. The network of footpaths from Lamlash to Brodick via Dunfion, which includes the Arran Coastal Way, are one of the most popular walks on Arran for both the local community and visitors. The visual impact of the proposed fish farm will degrade the scenic element of the area, and change it into what might be perceived as an industrial site. With tourism being the major wealth creator of Arran, this fish farm could do untold harm to the unique island environment, beautiful scenery and wildlife. No mention has been made of the colourful navigational buoys that will be needed to protect the site.

EXISTING FISH FARM IN LAMLASH BAY

 4. The North Ayrshire Local Plan states: “The Council is aware of the Community of Arran Seabed Trust [COAST] and is generally supportive of seabed  regeneration and marine conservation within Lamlash Bay, where the existence of maerl beds are under threat”.The placing of an intensive fish farm  adjacent to the maerl beds is in breach of this policy. To protect the environmental value of undeveloped coastal zones the Plan states that “Development shall not  accord with the Local Plan unless it is within a settlement, is associated with an existing development, there are specific operational needs for the  proposal to be located on the site and there are no feasible alternative sites available”. This development also breaches this policy.

5.      This proposed large fish farm will have considerable negative impact on the environment and wildlife in this area. The large feed system, diesel driven generator, underwater lights and considerable activity in the area will disturb the abundant wildlife population. Seals, sea otters and cetaceans are regularly seen along this shore. Peregrines, owls, ravens and fulmars nest in the area. Much of this wildlife has European Protection status. The existing marine life, including maerl scallops, lobsters and crabs, could be affected by the waste disposal from the fish farm. Fish excrement and chemicals [see 8 & 9 below] will be released into the surrounding water by the fish farm; both of these will end up on the shore which is a Site of Special Scientific Interest.  Marine Harvest say they considered 6 locations before deciding on the Clauchlands Site.  There was no consultation with the local population of Arran about where they thought it might be best placed. This demonstrates the complete disregard for the local community’s opinion about their environment.

6    In past years fish farms in Scotland have been used as a reason for giving employment to an area. At present there are many available jobs on Arran that can’t be filled, in fact many jobs are being filled by European Union labour bought to the island. This application shows 4 extra jobs but total employment of labour at Marine Harvest sites in Scotland has decreased quite dramatically over the last few years. All the fish farm food, supplies and services will be brought in by boat, using a Marine Harvest contractor; this will bring no financial benefit to the Arran community. The wages shown as being paid to the fish farm workers equals 0.000003% of Arran’s income from tourism. It is a fact that this Norwegian owned firm will bring very little benefit to the Arran people yet have a potential to harm the tourism economy of the island and its environment.

         FEED BROUGHT IN BY SHIP AT LAMLASH SITE

7. It is inevitable that farmed fish will escape into the wild during extreme weather conditions or accidents. Scientists say that farmed fish that escape can have an  impact on the genetic fitness of the wild fish population. It can affect the wild population’s competition for food, habitats and mates. Farmed fish can pass on disease  and parasites to wild fish. In the event of an equipment failure or accident, fish will inevitably escape in to the wild, as they have been doing around the  shores of Scotland in the past years. Marine Harvest reported that 15,746 farmed salmon escaped from their sites in 2006 and Pan fish reported 33,319 escapes.  The wild fish in the seas, burns and rivers around Arran and Ayrshire, used by tourists, will be exposed to these possibilities.

8. Marine Harvest calculates that the untreated waste discharge from this fish farm will be a minimum of 1012.51 tonnes of fish excrementevery 22 months. The fish  farm will also put a considerable amount of chemicals in to the waters to control disease which is prevalent in all fish farms [see item 9 below]. The proposed farm is  adjacent to Lamlash Bay which has been designated as an area for water sports and recreation in the Local Plan. A new outdoor centre is being built there costing  over £4 million, by North Ayrshire Council; the knowledge of these discharges could affect any parent’s desire to send their children to the centre. Scottish Water  has recently spent £3 million cleaning up the sewage in Lamlash Bay. To locate a large fish farm with its resultant waste discharges in this location would undo all the  good work carried out so far. Marine Harvest did not take account of the sewage outfall in their ES. Marine Harvest has said that much of the fish meal used at the  farm comes from South America. With ‘global warming’ a real threat to the planet and the air/sea miles that food is carried a current issue is another reason for  opposing this farm.

9. Marine Harvest and Pan Fish’s [They are both now the same company] record of managing fish farms efficiently in Scotland has been under scrutiny. For example:

Data obtained from SEPA under the Freedom of Information Act [but was not made generally available to Arran folk] reveals that in 2005 the St Molios site in Lamlash Bay [which is MUCH smaller than the proposed Clauchlands site]: 
used in April 152950 grams of SLICE (active ingredient Emamectin benzoate)
and used 96 grams of MS-222 (Tricaine Methyl Sulphonate)
and used 3 litres of FAM 30 (Iodine)
and used 10 litres of SOMPLEX Fatsolve (1-alkyl-1,5-diazapentane)
and in May had 2,245 mortalities (8,736 kgs of dead salmon)

[other months were less than hundred; another month had nearly 1,000 mortalities] 

 In Feb 2005, the St. Molios site breached the terms of its SEPA discharge consent by exceeding biomass by 1.36%

  Thus far in 2006 (January to September), the St Molios site:
- has released 29,541.13 kg of Nitrogen, 4,079.49 kg of Phosphorus and 94,777.777 kg of Total Organic Carbon
- has released 29.42917 kg of Zinc and 1.38855 kg of Copper (via feed only)
- had 28,155 mortalities (3,542 kgs of dead salmon) in February
- had 4,797 mortalities (768 kgs of dead salmon) in March
- had 6,441 mortalities (1,247 kgs of dead salmon) in April
- had 5,509 mortalities (6,692 kgs of dead salmon) in September

People are asking what is happening at St. Molios.  COAST is writing to Marine Harvest to ask.

Information has been received from the Scottish Executive on diseases at Marine Harvest’s Scotland sites:

The 'Disease' file reveals that Marine Harvest had problems during 2006 with 10 diseases.  Infectious Pancreatic Necrosis, Vibrio Species (Unidentified) and Vibrio Species (Histology) was reported at 6, 5 and 3 sites respectively.  Other diseases reported at Marine Harvest sites include: Adhesions (2), Aeromonas Hydrophila (1), Unidentified Bacteria (1), Flavobacterium Species (1), Gill Pathology (2), Moritella Viscosa (1) and Salmon Pancreas Disease (1).