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Responding to the North Arran Salmon Farm Planning Application

 

Scottish Salmon Company Planning Application for Millstone Point, North Arran

On Saturday 17th August 2019 the Scottish Salmon Company submitted their planning application for a new development off Millstone Point to North Ayrshire Council. The council’s planning committee have four months to consider this application.

So what can we do?
As members of the public, we have until 30th September 2019 to submit our comments on the planning application. Please see below for guidance on how to respond and some suggested content in response to the >900 page application.

All associated documents for this planning application can be viewed, with the option of downloading, by clicking on the link below or by copying and pasting it into your search bar:

https://www.eplanning.north-ayrshire.gov.uk/OnlinePlanning/applicationDetails.do?activeTab=documents&keyVal=PW6JPXLE04X00

There are two key documents worth reading which summarise the planning application:
1) Non-technical summary (viewable here).
2) Pre-application consultation report, detailing the views of the community regarding the development – collated from feedback at the public consultation events and Q&A sessions (viewable here).

All other documents are worth having a look at if you feel you can digest them all, but these are the two we recommend. If you would like to read a paper copy of any of the documents, you can do so at Brodick Library and the North Ayrshire Council Offices in Lamlash.

 

Taking Action

Ways to respond

Step-by-step guidance as to how to do this can be viewed here.

There are two ways to respond to this planning application:

1)  Online via the North Ayrshire Council planning website.

Here is an update from North Ayrshire Council on how to respond to this planning application.

All comments need to be submitted through the council’s online portal.

Submit your comments online.

The portal has a limit of 5,000 characters.  Should you wish to comment further you can either submit another comment or send a supplimentary email which can also include attachements.  If you do send an email, you should mention in your online comment that you will be also sending an email and please make sure that you send the email from the same email address you used for your online comment.  This will allow the council to match up the email with the online comment.

Further information about how to comment is available on the NAC website here.

2) Writing: F.A.O Mr Iain Davies, Planning, North Ayrshire Council, Cunninghame House, Irvine, KA12 8EE
copying to: COAST, Old Pavilion, Lamlash, Isle of Arran, KA27 8LS

Please ensure you use the planning application number as subject reference: 19/00609/PPM

What to include
Comments that will work well are:
– Comments specific to North Arran, not about salmon aquaculture in general.
– Those that comment on the effects on the landscape and seascape
– Those that highlight the impact on tourism and local economy.
– Comments regarding to the impact on wild salmon.

Additionally, the planning committee must take into consideration points outlined in the North Ayrshire Local Development Plan when looking at this application. Comments relating to these points are encouraged. Policy 25 directly relates to Aquaculture. There is an emphasis on the Council having a duty to consider any cumulative effects on a number of different areas: the landscape, seascape and visual amenity; the protection and enhancement of the wider physical environment; coastal and marine species (including wild salmonids) and habitats; and other users of the marine environment.

Specific Guidance on Key Points for Your Objection

Make your objection as short or as long as you wish; the important thing is that it is yours and it will then be counted clearly by North Ayrshire Council as another objection.  You may download the guidance as a WORD document here to assist you or read the same text below.

We have grouped some points to include in your own objections under these separate headings which are as follows:

Scottish Salmon Company and their ‘public consultation’

Socio-Economics

Environmental Impact

    Landscape and seascape

    Waste and chemical discharges

    Wild salmon and sea trout

    Iconic marine and coastal species (seals, cetaceans, basking sharks and otters)

    Seabed Habitats and Priority Marine Features

All points do relate directly to the documents in the application which are primarily the Socio-Economic Report, Environmental Impact Assessment, Planning Statement and the Pre-Application Consultation Report. Please take some points that you feel passionately about and agree with and rewrite or include them in your own text, all these points will be relevant to planning policies in the North Ayrshire Council Local Development Plan; the application breaches the following planning policies because it will damage our landscape, seascape and environment without any net benefit to the island’s economy: Strategic Policy 1: Spatial Strategy; Detailed Policies: Policy 15 – Landscape and seascape; Policy 16 – Protection of designated sites; Policy 22 – Water Environment Quality; Policy 24 – Alignment with Marine Planning; Policy 25 – Supporting Aquaculture

The top-line message here for the planner and the planning committee councillors is that: if the Council approves this planning application for a massive salmon farm in the waters of the North Arran National Scenic Area they will be contradicting their very own planning policies and allowing the Scottish Salmon Company to increase their profit for themselves and their shareholders while Arran’s coastal community have no net benefit; our people, businesses and wildlife will be required to suffer the effects of significant long term damage to our landscape and seascape, seabed habitats, wildlife, and the resulting damage to our tourist economy which, thousands of us are dependent upon for our income and island services. 

Scottish Salmon Company and their ‘public consultation’ 

  • Please put in a line or two about your own experience of dealing with the SSC in this section e.g. have they been respectful to you, did they answer your questions clearly, have they been transparent in their statements regarding environmental impact, jobs for Arran and their public engagement, did they offer you or your organisation funding or provide an unsolicited gift of a farmed salmon? 
  • In terms of corporate responsibility and animal welfare we question whether SSC has demonstrated that it is as fit to trade as it claims to be. The company has a questionable track record in terms of animal health as illustrated by cases at several of its salmon farms in Scotland. A shocking case last year at one of its farms in Loch Roag on the Isle of Lewis can only be described as a tragedy showing an extraordinary level of animal cruelty, with salmon in the cages being eaten alive by an infestation of sea lice. Further complaints this year of stressed and injured salmon at a SSC farm in Loch Sheildaig, the high levels of dead fish in their St Molios salmon farm near Lamlash and dead salmon reportedly being caught in fishing trawls near SSC’s Ardyne operations continue to raise serious questions about the animal welfare standards of SSC’s operation.

Socio-Economics 

  • The social and economic impacts report does not show any sustainable economic value coming to Arran (no new island jobs guaranteed of the 10 that they state in their planning application) only long term damage to our environment and reputation and therefore our tourist industry and our businesses. The Arran site is proposed to be highly automated, compared to existing sites.  Indeed, the Scottish Salmon Company’s (SSC) untested, and conceptual engineering for their, SeaQure system seems to be designed to minimise the need for manpower at all (for example in the removal of dead fish and net cleaning).   SSC’s estimate of ten new staff (not promised from Arran and maybe delivered direct by boat from off island to the farm) illustrates the trend for the company to concentrate their activities on larger automated sites, generating increased production but fewer jobs to maximise profit for their shareholders. Indeed, the SSC application states that their estimated 61 full time equivalent jobs across Scotland, repeated several times as a key figure, ‘may reduce with greater automation’ from 2021 onward.
  • The socio-economic report does not address in any robust way the significant risk to the islands primary industry-tourism-by a development that will have a tangible visual and polluting environmental impact and destroy the unique sense of place on the Islands NE Coast, in short the things that make Arran such an attractive place to visit (and live). From the SSC’s own figures in the application this farm will put untreated waste continually into the waters equivalent to a town at least the size of Troon; killing the seabed and damaging our wildlife Many Arran businesses are concerned about the potential effect on the 400,000 visitor £61 million tourist industry on Arran; there is potential for the visitor perception of Arran to be irreparably damaged as this company fails to take note of public opinion and move away from open cage salmon farming.
  • Mention is made by the SSC of the well-known issues related to an overall ageing population on Arran, the difficulty with available housing stock and the related difficulty for our workforce and for younger members of the Arran community, and their families, accessing accommodation. However, while iterating these points throughout the report, no direct solution is offered; what is implied is that the building of a fish farm will act as a white knight and have some sort of aspirational miraculous impact without making it clear how this will come about. In their public consultation they talked often about their award winning apprentice scheme but there is no commitment to this being operational on Arran. Fundamentally Arran does not have an unemployment issue we do have a housing issue for our existing workforce and to attract a larger currently needed workforce and this development only has the potential to exacerbate the issue rather than help it at the additional cost of damage to our landscape and seascape and hence our tourism dependant businesses.
  • The 10 new jobs are not defined and not guaranteed locally and anyway where would they be housed if they are local jobs; SSC write about supporting local housing in the application but this is not defined and their community support to date is cursory and is considered by many to be been aimed at getting opposition on board e.g., they state that they supported footpath construction on Holy Isle, in fact they were paid for this work,  they say that they support Arran Riding for the Disabled but this local organisation is sadly no more. All this is misleading and shows very little respect for the intelligence and culture of the people of Arran.
  • The section on Supporting Arran’s Objectives is vague nonsense and completely misunderstands what the objectives of Arran are. They write about ‘a best in class approach’ which is to do with this so called engineering ‘innovation’ in which they are investing. If it is so innovative why do they retain in the application all the harmful chemical, pesticide and antibiotic treatments that they have been using elsewhere and had so many problems with? There is no ‘innovation’ in their investment it is an untried and tested automated concept which will simply allow them to extract more money per employee, if it works, and will not reduce the local or cumulative impact on the environment and economy in any way whatsoever.
  • Despite the SSC statements to the contrary there is little evidence that salmon farming enriches our coastal communities, whether in housing, ferry services or otherwise. The only reason, as admitted by them in a public meeting when pressed, is that they want to site a new mega-farm off Arran is because they thought that they would face less planning opposition on our isolated coast and they need to keep growing shareholder value and returns; this is a pressing priority for them as the company is now currently a takeover target. One interpretation of why they have fast tracked their application with a vast amount of padding from consultants, and done so little substantial fieldwork on their EIA, and are promoting an unproven and so called ‘innovative’ new engineering concept is that they want to get this application approved ASAP to ensure they maintain their attraction as a takeover target.  An informed sceptic may justifiably ask that the detail in this application is actually so poor do they really wish to proceed with this development as presented or just hike the share price and cash out when taken over.
  • It is not clear where the site will actually be serviced from and there is also reference to staff living on the barge, which means that the staff could be shipped in and out by boat from off island. If the site is not on Arran, it is safe to assume that no direct salmon farm jobs will be generated on Arran itself. The point needs to be made that the persistent claims about the benefit to Arran occur as self-serving and misleading.
  • Creel fishermen and trawlers operate along the coast of the North Arran site and off Millstone Point. The sea lice chemical treatment (emamectin benzoate SLICE) in the salmon feed poses a significant potential risk to our shellfish. SEPA in its study of eight Shetland salmon farms has concluded that this chemical has the biggest negative effect on crustacean abundance and diversity. Use of this chemical therefore puts our wildlife and our fishermen’s livelihoods at risk.  The cumulative effect of this farm and the others in the Clyde and the financial risk to the commercial fishers are not considered in this application and need to be taken account of by the Council.
  • Alternative technologies and alternative locations have not been assessed adequately in the application. One alternative is to see the Scottish Salmon Company (SSC) investing their millions (£17 million of Capital Expenditure in first two years in the application) in land based aquaculture to still make use of the Scottish quality brand and use vacant, derelict brownfield and abandoned farm sites, and light industrial sites to farm salmon sustainably, without infecting our seas and precious wildlife with waste, lice and disease.  If we persist with growing open cage farming we will get left behind by foreign land-based competition and the Arran and Scotland food brand image will be damaged for everyone along with Arran’s image as a great tourist destination, which cares about its landscape and seascape. Peel Ports in part of their Hunterston Master Plan have proposed a land based salmon farm with an annual GVA of >£5 million and 60 jobs, the abandoned Big Idea site on the Ardeer Peninsular could also be a possible site for land based fish farms.  These parts of mainland North Ayrshire would welcome investment for sustainable employment and these brownfield site alternatives have not even been considered by the Scottish Salmon Company in their planning application. They have opted instead for the same old, same old visual impact on our landscape and seascape and using their farms as open sewers into our waters.  It is not sustainable and not what Arran’s community and most businesses want to be associated with.

 

Environmental Impact

Landscape and seascape

  • This stretch of coastline is of significant recreational value to Arran.  The Arran Coastal Way was designated as one of Scotland’s Great Trails by Scottish Natural Heritage in June 2017 and attracts visitors from all over Scotland and the World. The visual and sound impact will be massive and extend for over a kilometre along the Coastal Way and be visible over an area equivalent to 33 football pitches.  This would be a disaster as it would ruin one of the treasures and major visitor attractions of Arran.
  • Visual, light and sound impact in a designated scenic area of national and local importance and its effect on the tourist driven economy of Arran is a crucial point. All the visual impact information in their public video showed a lack of walkways and the spine, thus the apparent visual impact was reduced and was misleading to the public.  The SSC imagery is commonly shown as viewing the proposed farm from sea level when in fact the Arran Coastal Way is elevated above sea level along this part of the coast, which increases the visual impact by several orders of magnitude.
  • The visual intrusion of the cage structure is made more prominent by the fact there will be workboats visiting the farm every day, with more vessels present when treating and harvesting the salmon. This will just further emphasise the presence of an industrial farming system in the middle of a quiet and isolated area.

Waste and chemical discharges:

  • Would it be OK to site a huge USA-style intensive factory farm raising poultry or pigs in either Glen Rosa or Glen Sannox?  I think not! Then why would it be OK to site a mega, open-cage salmon farm off Millstone Point along the north east of Arran; an area of wild coastal scenic beauty? The proposal is for a near automated salmon feedlot discharging some 2000 tonnes of untreated excrement mixed with treatment chemicals each year. It is a vast amount of sewage going into the sea around an island which has had millions spent on it by Scottish Water to clean up the human sewerage and treatment systems.
  • The SSC’s own figures in the application show that this farm will put untreated waste continually into the waters equivalent to a town the size of Troon (14,000 people); killing the seabed and damaging our wildlife.  If we used Professor Paul Tett’s figures from the SAMS report to the ECCLR committee (2018) then the estimate for a farm this size is that it will produce waste equivalent to a town of 66,000 people going into our sea untreated. The actual figure may fall somewhere in between.
  • Marine Scotland mapping shows the SSC farms in Lamlash Bay and Loch Fyne associated with a high and medium biotoxin (toxic algae) risk to shellfish respectively (this east Arran high risk area is the only high risk area shown in the whole of Scotland). We do not need another salmon farm in between these areas discharging salmon sewage, which will increase the biotoxin risk and become more lethal as we experience global warming. Toxic algal blooms were responsible for a major salmon mortality event at an SSC farm in Loch Fyne this year. We need to be continually moving toward cleaner seas and reducing the artificial nutrient input into them. Clean. biotoxin risk free seas around Arran will encourage investment in local sustainable shellfish and seaweed farming, which will add to the Arran economy with no damage to our environment. In fact, sustainable shellfish farming will enhance our seas by helping to clean them up by filtering the seawater and produce a farmed  Arran product that we can be proud of.

Wild salmon and sea trout

  • SEPA, SNH, Marine Scotland, the cross-party ECCLR and RECC parliamentary committees have done a lot of work in the last two years highlighting the risks associated with open-cage salmon farming (e.g. sea lice on wild salmon and sea trout, chemicals on shellfish, waste on the seabed) and these are not adequately addressed or acknowledged in the application, the socio-economic report or the Environmental Management Plan.
  • SSC, SNH and Marine Scotland do not have adequate data on wild salmon migration routes around Arran and for the SSC to claim that their salmon farm and Environmental Management Plan will be ‘best in class’ is false; they cannot possibly have a plan to protect wild salmon if they have no data on where they are migrating along the coast of North Arran.
  • The reason that there are no fish farms down the east coast of Scotland is because the loud voices of the wealthy owners of the east coast salmon rights (e.g. Tweed, Dee, Spey and Tay) are rightly concerned about the pressures on the wild salmon runs in their rivers and this has lead to a ‘presumption against’ salmon farms on the east by the Scottish Government. While here on the west coast the Clyde wild salmon are under even more extreme pressure from the existing 16 farms and the 6 more that are planned, and this is of great concern to the Argyll District Salmon Fishery Board and many others. The SSC assertion that migration is only likely to occur down Kilbrannan Sound and not through the proposed site is unsubstantiated opinion and is a misleading, disingenuous and self-serving neglect of the risk to our wild salmon and sea trout.
  • The structure, lights (above and underwater), feed and sewage from this farm will act as a wildfish aggregation device and attract local and passing wildfish outside and inside the cages (this is a well-known effect).  It is unknown what the effect of this fish aggregation will have on local mammal and predatory wildfish behaviour and the increase of risk of sea lice infection of migrating wild salmon and infectious disease being passed to the wild animal population. All these risks are known to occur and yet this effect of wildlife aggregation around such a large farm is not taken account of in the SSC Environmental Management Plan within the planning application.

Iconic marine and coastal species (seals, cetaceans, basking shark and otters) 

  • Arran is the most southerly location on The Hebridean Whale Trail, and the Clyde Marine Mammal Project have undertaken extensive cetacean hydrophone surveys in the Clyde. The NE coast of Arran from Corrie around to Lochranza is a well-known hotspot for minke whales, dolphins, porpoise, seals, basking sharks and otters. These protected animals will be seriously affected and the peace of the Arran Coastal Way will be shattered by the 32 (yes 32!) deafeningly loud, acoustic deterrent devices that they plan to attach to the cages. They will retain the last resort of shooting ‘persistent problem seals’. Our visitors and locals alike walk this way and boat this way with the hope of seeing these iconic species.  The chance of this wildlife experience will be destroyed.

Seabed Habitats and Priority Marine Features 

  • The seafloor observations in the EIA report comprise a cursory coverage by video using a Remotely Operated Vehicle (ROV) with a camera. No mandatory benthic grab samples were taken to determine the baseline assemblages of species living in the sediment across the wide area of the site as required by the Council scoping opinion.  The few video transects undertaken are inadequate to determine whether there a sensitive Priority Marine Features present in the area which will be affected directly by the waste and chemicals.
  • A rare Northern Sea Fan was observed and noted in the report but not considered significant by the Scottish Salmon Company to merit any further investigation. However, published records show that this is the most southerly record of a Northern Sea Fan on the west coast of Scotland and certainly in the Clyde Region. So why not investigate further to determine what species are present before submitting an inadequate EIA with the aim of building an industrial salmon farm on top of it, killing it off with waste and maybe many more in the area.
  • Cumulative effects of this planned farm are unknown and not accounted for in the application. However, the Council and SSC have a duty to take cumulative effects into account (stated in the Local Development Plan). 16 salmon farms already exist in the Clyde region, 6 more new applications are proposed along with 3 expansions of existing farms, without any study of their cumulative effects. EU Law also states that a sector plan needs a Strategic Environmental Assessment, this has not been undertaken for the open cage fish farming sector in Scotland who wish to double the size of the sector by 2030.
  • Scotland’s statutory Environmental Impact Assessment regulations 2017 (EIA) are very clear in that the EIA report submitted as part of the planning application must follow the requirements in the scoping opinion issued by the Council and that the SSC must use current knowledge and methods of assessment at the point at which scoping is undertaken. It is clear that the EIA does not meet these criteria, a few breaches are listed below:
  1. No benthic survey as detailed in SEPA guidelines was undertaken and this is a mandatory requirement in the Council scoping opinion.
  2. No hydrodynamic and cumulative effects modelling was undertaken and this is a mandatory requirement in the Council scoping opinion.
  3. ‘Old’ AutoDEPOMOD modelling software was used to model the seabed impact of the waste dispersal from the 5000 tonne single site as two sites each of 2500 tonnes, which it clearly is not and is a single very large site. The validity of the AutoDEPOMOD model has been debunked by SEPA and SAMS themselves and is not considered a current valid method of assessment as it has been superseded by NewDEPOMOD modelling software which has been in use and available to the industry for many months.

 

 

 

 

Photo credit: Corin Smith – Inside Scottish Salmon Feedlots

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