Public Document Pack
Argyll and Bute Council Comhairle Earra Ghaidheal agus Bhoid
Customer Services Executive Director: Douglas Hendry
Kilmory, Lochgilphead, PA31 8RT Tel: 01546 602127 Fax: 01546 604435 DX 599700 LOCHGILPHEAD e.mail –douglas.hendry@argyll-bute.gov.uk
17 April 2013
NOTICE OF MEETING
A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be held in the MAIN HALL, CORRAN HALLS, THE ESPLANADE, OBAN on WEDNESDAY, 24 APRIL 2013 at 10:00 AM , which you are requested to attend.
Douglas Hendry Executive Director - Customer Services
BUSINESS
1. APOLOGIES FOR ABSENCE
2. DECLARATIONS OF INTEREST (IF ANY)
3. LAKELAND MARINE FARMS LTD: RELOCATION OF ARDMADDY FISH FARM COMPRISING 12 NO. 100M CIRCUMFERENCE CAGES PLUS INSTALLATION OF FEED BARGE: PORT NA MORACHD, SEIL SOUND (REF: 11/01066/MFF) Report by Head of Planning and Regulatory Services (Pages 1 - 118)
PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
Councillor Gordon Blair Councillor Rory Colville Councillor Robin Currie Councillor Mary-Jean Devon Councillor George Freeman Councillor Fred Hall Councillor David Kinniburgh Councillor Iain MacDonald Councillor Alistair MacDougall Councillor Robert Graham MacIntyre Councillor Donald MacMillan Councillor Alex McNaughton Councillor James McQueen Councillor Sandy Taylor Councillor Richard Trail
Contact: Fiona McCallum Tel. No. 01546 604392
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Argyll and Bute Council Development Services
Delegated or Committee Planning Application Report and Report of handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2008 relative to applications for Planning Permission or Planning Permission in Principle
Reference No : 11/01066/MFF Planning Hierarchy : Local Development Applicant : Lakeland Marine Farms Ltd. Proposal : Relocation of Ardmaddy fish farm - comprising 12 No. 100m circumference cages plus installation of feed barge Site Address : Port Na Morachd, Seil Sound
DECISION ROUTE
Local Government Scotland Act 1973
(A) THE APPLICATION
(i) Development Requiring Express Planning Permission
• Formation of Marine Salmon Fish Farm comprising 12 No. 100m circumference cages, walkways, mooring grid and associated lines, • Installation of feed barge; • Installation of underwater lighting.
(ii) Other specified operations
• Servicing from existing shore bases at Loch Craignish and Croabh Haven; • Removal of 18 No. 24m x 24m steel cages from existing site at Ardmaddy North and relinquishment of lease.
(B) RECOMMENDATION:
It is recommended that permission be granted subject to:
i) a pre-determination hearing be convened in response to the number and complexity of the representations received;
ii) the conditions and reasons set out in this report.
(C) CONSULTATIONS:
Scottish Environment Protection Agency (27.07.11 & 11.12.12) – In order to address the likelihood of significant effects upon the Firth of Lorn Special Area of Conservation (SAC) SEPA will require to undertake a Habitats Directive ‘appropriate assessment’ as part of its Controlled Activities Regulations (CAR) licence application, and until this
Page 2 process is completed it is not possible to say whether the biomass proposed will be licensable under CAR. Subsequent response in 2012 confirming that a CAR licence has been granted and supplying a copy of the ‘appropriate assessment’ undertaken by SEPA in support of that consent.
Comment: Pollution control is exercised by SEPA and government advice to planning authorities is not to seek to use the planning process to duplicate other regulatory regimes. Where multiple consents are necessary there is no prescribed order in which they should be obtained. However, in view of the importance of potential pollution effects upon protected habitats and species in this particular case, and given the large numbers of representations to the planning application being related to pollution issues, the applicants were advised by planning officers to agree to this planning application being held in abeyance, in order to allow them to pursue a CAR licence application in advance of the determination of the planning application, so that that the consequences of pollution could be assessed by the appropriate agency and conclusions reached, outwith the planning process. An application was duly submitted and processed by SEPA, who undertook a Habitats Regulations ‘appropriate assessment’ in the consideration of that application. In view of the number of adverse third party representations to the CAR licence application, the intended decision by SEPA was the subject of review by Scottish Ministers before being issued. No intervention in the intended course of action arose as a consequence of this and a CAR licence was duly granted.
Scottish Natural Heritage (28.08.11 & 26.02.13) – in view of the likely significant effect on the Firth of Lorn Special Area of Conservation the planning authority is advised to undertake an ‘appropriate assessment’ having regard to the conservation objectives of the SAC addressing the transport of organic wastes and chemotherapeutants from the site. Further comment will be made once the AA has been concluded.
In terms of European protected species the proposal has the potential to affect otters and cetaceans. It is not expected that the site would affect otters significantly. The deployment of acoustic deterrent devices to deter seals could have consequences for porpoises as whilst research indicates that they will avoid areas where ADD’s are in operation (but will return once they are switched off), continuous operation could have the effect of excluding them from the Sound. SNH consent should therefore be required for the deployment of ADD’s at this location. Whilst the faunal analysis of the seabed shows a relatively diverse and abundant community no benthic impacts prejudicial to national interests have been identified. Predators such as seals, otters and pisciverous birds are common in this locality. The applicant considers that double nets are impractical in this location due to strong tidal currents and SNH concurs that tensioned nets with anti-chafe panels as employed at many other sites will be sufficient to minimise risk of escapes. The applicant’s predator control plans and risk assessments require some updating (subsequently completed). Whilst there are no salmon rivers within 15km, sea trout will frequent the area year round. Sea lice treatments to SSPO Code of Good Practice Standards and operation in accordance with the local Farm Management Agreement will minimise impacts on wild fish, as will the intended use of well boats for chemical treatments, rather than the more traditional tarpaulin method employed at the existing site. White cluster anemone is present in the vicinity of the site and the SEPA CAR assessment should address consequences for this Priority Marine Species.
In terms of landscape impacts as the proposal does not affect any national designations SNH has no objections on landscape, visual or recreational/amenity grounds. Localised impacts could be reduced by repositioning the barge to the south end of the site where it would be better screened by higher ground on Torsa to the west . Whilst the area is frequented by tour boats, yachts and kayaks and the development will give rise to
Page 3 localised impacts these are not considered to be such that they will significantly affect the overall experience of the Sound and the wider Firth of Lorn.
Following the production of the Council’s draft ‘appropriate assessment’ SNH has confirmed its satisfaction with the content.
Comment: The option of relocating the feed barge to the southern end of the site has been resisted by the applicants, as for operational reasons a barge location at the least exposed end of the site is preferable as it presents less risk to containment in the event of the barge moorings being compromised in storm conditions. The applicants have however agreed to reduce the scale of the barge from 26m x 18 m to 14m x 10m in order to lessen its visual impact and amended plans to that effect have been submitted.
Marine Scotland Science (02.08.11) – No objection. Note the intention to use well boats for sea lice treatments and the potential to use Wrasse as a supplementary means of lice control. There are no major Atlantis salmon fisheries within 15km so wild salmonids in this area are likely to be marine phase sea trout throughout the year and migrating salmon. Provided the site is operated in accordance with the existing Farm Management Agreement for the area, in accordance with the SSPO Good Practice Guidelines and the necessary steps are taken to control lice numbers and to maintain equipment to minimise risk of escapes, then impacts upon wild fish will be minimised. It is recommended that it should be a condition of any consent that the existing site at Ardmaddy North is relinquished.
Argyll & District Salmon Fishery Board (11.07.11) – No specific objections but it is noted that the development involves a significant increase in biomass and that it would be preferable for this to be maintained in the initial period following relocation to enable the applicant to demonstrate that SSPO Code of Good Practice sea lice levels can be achieved. In the event of an approval, it should be a requirement that the current site be closed and the lease surrendered.
Historic Scotland – response awaited.
Northern Lighthouse Board (08.07.11) – no objection but advice given as to navigation marking and lighting requirements.
Royal Yachting Association – have indicated verbally that they have no comment to make in respect of the planning application and that they will reserve any comment for the Marine Licence application as and when that is submitted.
Clyde Fishermen’s Association (21.07.11) – object to further development of the wider fish farming industry in general and this application in particular due to the adverse consequences of pollution in the marine environment and the general unsustainability of farming fish.
Mallaig & North West Fishermen’s Association – no response
Council’s Marine & Coastal Manager (10.08.11) – the scale of the existing and proposed sites are similar in terms of surface equipment area and the characteristics and designations of the landscape are similar for both sites although the proposed site occupies a more confined section of the sound, where its visual presence may be increased. The RYA sailing route hugs the west side of the channel and the proposed site does not conflict with this. The Marine Licence process will address navigational issues. Risk to wild salmonids is unlikely to significantly increase if the Farm Management Agreement continues to be adhered to and the proposed mitigation is implemented, given that Marine Scotland considers the modelled availability of sea lice
Page 4 treatment to be sufficient for the biomass proposed. SEPA’s CAR licence process will include consideration of potential effects on the Firth of Lorn SAC. Three seal haul outs are within 2km although the applicant’s three sites around Shuna are closer to larger haul outs. The use of Acoustic Deterrent Devices in narrow water bodies may restrict the use of the area by cetaceans and advice should be sought as to whether a licence from SNH would be required for their deployment.
Council’s Biodiversity Officer (25.07.11) – no objection but further comment sought about potential effects upon marine species. Concern that the proposal will reduce the width of the channel available for dolphin and porpoises.
Scottish Wildlife Trust (26.09.11) – objects to the development on the grounds that in the absence of an Environmental Impact Assessment there is insufficient information to enable the required Appropriate Assessment in terms of implications for the Firth of Lorn Special Area of Conservation, and therefore the process is unsound. The SAC is of international conservation importance and the wildlife it supports is of tourism value. For development to proceed, it must be concluded beyond reasonable scientific doubt that the implications for the protected rocky reef habitat and the species it supports will not have an adverse impact on the integrity of the SAC. Failure to employ double nets and the consequent need to employ acoustic deterrent devices or the licenced shooting of seals, would not lead to seal shooting as a ‘last resort’, as legislation requires. Porpoise dolphin and otter use the sound regularly and would be disturbed by the deployment of ADD’s. Local wild salmon and sea trout stocks have collapsed in recent years and sea lice associated with the development will be likely to adversely affect these protected species. The transport of organic waste and chemotheraputants from the site to the SAC would be contrary to its conservation objectives and would adversely affect the integrity of the designation. Given the presence of rock reefs and complex tides, conventional deposition modelling is not an appropriate method for predicting likely effects. Priority Marine Features such as white cluster anemone to the north of the site are likely to be affected reducing their value as dive sites contrary to the interests of the tourism economy.
Kilninver & Kilmelford Community Council (14.02.13) – have objected to the proposal on the grounds that the development will cause noise light and water pollution, and lead to rubbish being washed up on local beaches. It is also considered that the development will disadvantage the local tourism economy and could pose a threat to navigation and the interests of wild fish. The community support smaller scale aquaculture developments but consider that this is too prominent and conspicuous site for the scale of development proposed.
Seil & Easdale Community Council (04.08.11) – have objected to the proposal on the grounds that the area is one of scenic value and of importance to yachts, tour boats and other recreational craft, which collectively support the local tourism economy. The presence of the farm would narrow the channel and make it more difficult to avoid the rocks off Torsay Island (sic). There is concern locally that the development will not be in the interests of wildlife tourism, and also that consent for additional pollution is being sought given the expense of the Seil waste water treatment scheme. It is recognised that the Council has to balance economic arguments with the environmental disbenefits of the proposal, but that in this case protection of the environment should prevail. If the development proceeds, consideration should be given to reducing projection out into the channel, reducing the impact of the feed barge, using double netting as opposed to seal scarers and control over lighting.
Luing Community Council (02.08.11) – object in terms of concerns they have as to the effects of the proposal upon wildlife, tourism, sailing and recreational activities due to pollution in the vicinity of Luing and the Firth of Lorn Special Area of Conservation.
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Luing is heavily dependent upon tourism which is a key provider of employment on the island unlike fish farming. They urge that an environmental impact assessment and appropriate assessment should be used to inform the decision.
(D) HISTORY:
The site benefits from a Crown Estate lease for a mussel farm (AR-3-6-17) although the site is not currently equipped. No objection was raised by the Council to that development (03/00843/MFF).
A Crown Estate lease is in place for a salmon farm to the north of the site at Ardmaddy North (AR-3-6-6). This is currently equipped by 18 No. 24m x 24m steel cages.
The application site benefits from a CAR licence CAR/L/1099909 granted in December 2012.
It is intended that the proposal will supersede the shellfish site and that the lease for nearby fin fish site, which is also in the control of the applicants, would be relinquished and the equipment removed, in the event that this larger replacement farm at Ardmaddy South is consented.
(E) PUBLICITY:
The proposal has been advertised in the local newspaper (14.07.11 and 25.08.11) with the publicity periods having expired on 15.09.11.
(F) REPRESENTATIONS:
(i) Representations received from:
Objections to the proposal have been received from 814 third parties along with 8 supporters and 2 neutral representations. Names and addresses of those having submitted representations are listed in an Appendix this report. The grounds of objection and support are summarised below. It should be noted that a very high proportion of the objections take the form of standard template letters and e-mails.
Support for the proposal
• Aquaculture is an industry of the future and regulation in Scotland is amongst the highest in the world;
• Fish farming is a valued component of Argyll’s and Scotland’s economy providing opportunities for growth in a region where other opportunities are limited;
• The development presents opportunity to maintain or create jobs, both directly and indirectly;
• Fish farming produces a valuable product in the global market place, is one of our few export success stories and should be supported;
• The unscientific clichés advanced by objectors are misleading and inaccurate. When reviewing public comments please remember that many, including young people, are dependent on the aquaculture sector.
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Objections to the proposal
Application documentation and procedure
• The scale of the site relative to the existing site has been misrepresented by the applicant who has advanced it as a reduction whereas in practice it represents an enlargement. It is requested that the location of the site should be marked by buoys for the purposes of any committee site inspection;
• The Planning Authority have described the proposal as a relocation of an existing site whereas it is actually a new enlarged site. It cannot be legitimately regarded as a relocation given the difference in scale;
• The applicants refer to the site having an existing use as a mussel farm whereas the site is not in use and has not been in use previously for this purpose;
• The application ought to have been accompanied by an Environmental Impact Assessment;
• The application ought to be subject to ‘appropriate assessment’.
Comment: The application has been described by the applicant as a relocation as the intention is that it should be a replacement for their existing fish farm at Ardmaddy. Likewise, it was advertised by the Planning Authority as a ‘relocation’ so as not to mislead interested parties into believing that a second farm was proposed in the locality of the existing site. In order to clarify that the proposed development is intended to be an enlarged facility (rather than a straight replacement for the equipment at the existing site), the proposal was advertised a second time, in order to make entirely clear the nature of the equipment proposed.
The aggregate area of the surface equipment is a reduction in that at the existing site, although the extent of the overall surface area of the site is greater, as circular cages have larger intervening areas of water than the more compact arrangement of square pens found at the existing site.
Although the site has not been equipped for mussel farming it maintains a Crown Estate licence for such and would be capable of being so used without the requirement for further consent. The existence of the licence and the ability to occupy the site in accordance with the terms of the lease is a material planning consideration.
The proposal was ‘screened’ for the requirement for an Environmental Impact Assessment by the Planning Authority in advance of the application being submitted. Following consultation with interested bodies such as SEPA, SNH and Marine Scotland it was determined that as a relocation and enlargement of an existing site, an Environmental Statement would not be required in this particular case.
To satisfy the requirements of the Habitats Regulations, an ‘appropriate assessment’ has been carried out by the Planning Authority drawing upon the conclusions of the appropriate assessment undertaken by SEPA in the processing of their CAR licence. This appears at Appendix B to this report.
Objections founded on planning policy considerations
• The development would be harmful to a designated Area of Panoramic Quality and the Firth of Lorn Marine Consultation Area which are designations intended to
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protect the local environment.
Comment: Consideration of the effect of the development on the landscape and seascape of Seil Sound is required in the context of that associated with the current fish farm equipment. Local Plan policy LP ENV 10 accords the scenic qualities of the area regional importance. However fish farms are commonly located in scenic designation in Argyll, including National Scenic Areas which are accorded higher status in landscape terms. The development plan status of the area is not such as to preclude development but requires careful consideration of the landscape implications of development. The Firth of Lorn Marine Consultation Area is one of biodiversity interest prompting consultation with Scottish Natural Heritage. It is not a development plan designation which presumes for or against development.
Objections related to pollution considerations
• The doubling of biomass will increase the problems presented by the existing farm and will threaten sensitive marine ecosystems. Sites of this scale should be located further offshore and inshore sites should be operated at reduced stocking densities with enhanced containment;
• The site will produce large quantities of faecal waste well in excess of the produced by the local community and this should be considered in connection with that produced from consented fish farm sites in the area in terms of its cumulative consequences for the environment;
• The proposal will lead to excesses of nitrates, phosphates and other pollutants will contribute to a return to inappropriate levels of pollution in the Sound (in part addressed by the Seil wastewater treatment works). Given the £11m spent on upgrading the sewage treatment system for the small community at Seil in order to improve water quality in Seil Sound, it is perverse to countenance such an additional polluting form of development.
• Although a CAR licence has been granted by SEPA, they do not have the resources to regularly monitor sites so the industry is largely self-regulating which is worrying. There is reason to suspect that SEPA’s conclusions were flawed being based on the application of a standard computer model which may not relect the specific local conditions.
• The applicants existing site has in the past been graded ‘unsatisfactory’ due to impacts on the seabed extending beyond SEPA’s allowable zone for deposition about the cages. Whilst the applicant and SEPA consider that the new site exhibits better characteristics this conclusion relies on modelling which is not suited to contained stretches of water with wide variations in speed and direction. As modelling did not appear to represent actual experience at the existing site, there is doubt about its reliability here.
• The means by which mass and routine fish mortalities are to be disposed of has not been addressed as part of the application;
• The applicants have in 2006 previously pleaded guilty and have been fined £1000 for overstocking a site at Shuna.
Comment: Concerns regarding the polluting effects of development and the associated consequences for habitats and species appear to be the principal grounds for objection to the application. Although there is multiple consenting regime applicable to fish
Page 8 farming, there is no prescribed order in which those consents should be obtained. Given that these concerns related to issues controlled by SEPA under separate regulation, and having regard to the government cautioning planning authorities against the improper duplication of other consenting regimes, it was considered appropriate in this case that these matters of public concern be addressed in the first instance via a CAR licence application, in order to confirm the consentability of the development from a pollution control perspective before going on to determine the planning application with reference to those matters material to the application. It should be borne in mind that part of the driver for this application is to move operations away from the site at Ardmaddy North to a location which is more favourable from a SEPA pollution control point of view.
The applicants have concurred with this approach, and further to extensive public representation to the CAR licence application which followed, following review of the matter by Scottish Ministers at the end of 2012 a CAR licence was subsequently issued by SEPA. That consent permits maximum biomass to be held on the site and licences permissible quantities of chemical treatments for use at the site. Although third parties continue to express doubt as to the reliability of SEPA’s conclusions in the matter, the granting of the CAR licence is a matter of record and its validity cannot be questioned as part of the adjudication of this planning application. SEPA has addressed the capacity of the receiving environment to absorb the cumulative impact of multiple fish farm sites and the associated consequences of designated habitats and species as part of its assessment of the CAR licence application and has undertaken an ‘appropriate assessment’ relative to the pollution consequences upon the nearby Firth of Lorn SAC.
Reference is made to the apparent conflict between the additional pollution associated with this proposal and the costly waste water improvements implemented at Seil. These were borne out of European obligations upon Scottish Water and were driven by problems related to bacterial levels affecting shellfish waters, not by nitrogen or phosphorous enrichment. Human waste and fish farm waste are not therefore directly comparable in terms of their effects on the marine environment.
The disposal of fish mortalities on a routine basis or in the event of mass mortalities is not subject to planning control. This is an operational matter for the applicants and is regulated by SEPA (as waste) and by the Council’s animal welfare officers (animal by- products). Typically, small scale mortalities are dealt with by way of incineration locally with larger quantities being disposed of by specialised contractors at sites licenced to handle this category of waste.
The track record of the applicants in the operation of other sites is not a material planning consideration. Infringement of the terms and conditions of site licences is a matter for SEPA to enforce as necessary.
Objections in respect of marine and nature conservation interests
• The site will give rise to adverse consequences for wild salmonids, common and grey seals and cetaceans and would therefore be contrary to the interests of biodiversity;
• The site is located too close to the Firth of Lorn Special Area for Conservation and the seal haul out in Cuan Sound;
• Disrespect for the marine environment to the detriment of marine life and its habitat shows a lack of human compassion;
• The use of Acoustic Deterrent Devices to scare predators away will also affect
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cetaceans, such as the porpoises which are often seen in the Sound. These are protected by legislation and distress and adverse effects upon their hearing cannot be ruled out. The use of locally triggered devices over short periods could still pose a problem in that regard;
• Failure by the applicants to employ double netting presents prospect of wildlife entanglement, presents greater risk of escapes to the detriment of wild fish and leads to the unnecessary use of seal scarers and avoidable seal shooting. Development which poses a threat to seals and their pups ought to be rejected;
• The Seal Protection Action Group opposes the shooting of seals and believes that non-lethal predator strategies should be adopted;
• The Salmon & Trout Association objects on the basis that the development is likely to have an adverse impact upon migratory salmon and on sea trout as a result of sea lice propagation and escapes of farmed fish. No expansion of production should be allowed unless closed containment units are employed;
• As an ex local fisherman I have experienced the negative impact of fish farm development on the environment over the last twenty years and development of this type should be located further off shore;
• The developer should be required to underwrite independent monitoring of affected ecosystems;
• There is evidence of chemical treatments at fish farms proving harmful to shellfish populations.
Comment: The consequences of the presence and operation of the site upon marine habitats and species are clearly important issues for third parties, arising in part from the pollution consequences of development, but also from other matters such as sea lice propagation from farmed to wild fish, risk of escapes, deployment of acoustic deterrent devices and the prospect of seal shooting. Neither Scottish Natural Heritage, Marine Scotland nor the District Salmon Fishery Board have raise objections to the proposal on nature conservation grounds. The Habitats Regulations ‘appropriate assessment’ found at Appendix B has concluded that the proposal will not affect the integrity of the nearby Firth of Lorn Special Area of Conservation, which supports the conclusion reached by SEPA in their assessment of the preceding CAR licence application.
The consequences of the development for cetaceans and seals is clearly an emotive issue. The applicant’s experience is that the tensioned netting system proposed at this site will provide adequate containment and protection against predators; a position which is accepted by SNH. It reflects current industry practice across Scotland and the applicant’s practice at other sites in Argyll including sites in proximity to seal haul outs. The applicants do not routinely use acoustic deterrent devices (ADD’s) and currently have none deployed on their sites across Argyll. Only one of their sites has been fitted with ADD’s in recent years and that was for a temporary period as part of a university research project. However, in order to secure ‘Freedom Foods’ accreditation the ability to deploy ADD’s as an option is required as it is necessary to demonstrate that in the event of persistent attacks by a rogue seal, all non-lethal methods have been employed in preference to recourse to seal shooting. SNH have requested a condition requiring details to be approved of the type and means of deployment of ADD’s should they become required at some point in the future. In terms of seal shooting, this is licenced by Marine Scotland and is not a material planning consideration. Annual returns to the
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Scottish Government indicate that in 2012 one seal was shot at the applicant’s existing site at Ardmaddy. No seals have been shot at that location this year to date.
In terms of wild fish, the site is not close to important salmon rivers, although will be subject to the presence of salmon in the migration season and sea trout on a year round basis. The view of Marine Scotland is that provided the applicants adhere to the Scottish Salmon Producer’s Organisation ‘Code of Good Practice’ (it is a requirement to demonstrate compliance to maintain membership) and treatment is available in sufficient quantities to control sea lice to CoGP standards, then the interests of wild fish should be adequately protected. Given that a CAR licence has already been granted it is already known that sufficient licenced treatments are available to the applicants at this site. The applicants propose to use a combination of in-feed treatments and well- boat treatments. The latter are to be employed in preference to net shallowing and in situ treatment, and this will improve efficacy and reduce the quantities of pollutants released into in the marine environment.
Objections in relation to landscape, visual and amenity considerations
• The height of the net structure above the cages and the installation of a concrete feed barge give the development an industrial appearance;
• This development is proposed in a sensitive area of natural beauty where the barge, underwater lighting and the extent of the mooring area will impair views. It would be a dereliction of duty to sacrifice natural beauty to commercial interests;
• The south east coast of Seil Sound is unspoiled and identified by SNH as Craggy Coastline. There is a long established walking route from Ardmaddy to Loch Melfort which affords magnificent views. Development of this nature, which would not be countenanced on land, would be an act of environmental vandalism;
• Lighting will be intrusive given the absence of light sources in the area and the fact that indirect glow will affect a much wider area dependant on atmospheric conditions, even if the direct effects of light are localised or not significant at sea level;
• Noise from the feed barge generator would be intrusive in an area of low ambient noise, particularly as it would operate at night as well as during the day. Low frequency noise would be propagated long distances across open water. Generator noise from the site at NW Shuna can be heard at Toberonochy 3 miles distant on a calm night;
• The development will contribute to flotsam which is washed up on local beaches;
• The occupier of Kilbrandon House, Seil demands a report on the sound and visual impact on the property.
Comments: Given the location of the site within a designated Area of Panoramic Quality which accords the value of the landscape/seascape regional status, it is necessary to give consideration as to the visual and landscape effects of the development relative to the site to be removed from within the same designation, and the prospect of a mussel farm being located within the application site in accordance with the Crown Estate lease already held for such. This is addressed in Section C of Appendix A below. Site lighting is confined to one navigation light on the proposed feed barge plus underwater lighting for maturation purposes. The latter would not be visible at a distance nor at close quarters from sea level, as such underwater lighting is generally only visible from
Page 11 elevated vantage points. Given the absence of transport routes or occupied buildings along the adjacent coastline it will not present an issue at this site, as locations overlooking the site will not be frequented during the hours of darkness. The feed barge proposed is a type in use by the applicants at other locations in Argyll. The modern type of generator employed is contained within the concrete structure of the barge and from experience at those locations is not audible other than at close quarters. Notwithstanding the low background ambient noise levels which would be a feature of still nights, the distance to sensitive receptors is such that noise nuisance would not produce amenity issues of significance associated with the operation of this site. Kilbrandon House is approximately 2km distant from the application site, which would move approximately 0.9km further away from that property than the existing site.
Objections in relation to recreation and tourism interests
• The development will adversely affect local tourism related employment which is founded upon wildlife and the environmental and scenic qualities of the area. By comparison fish farm related employment is negligible;
• Scotland’s landscapes are already being devalued by wind turbines, power lines, inappropriate forms of rural development, shellfish and fin fish farms so a lot more common sense is required before such developments are allowed to go ahead;
• This is an area of scenic beauty and an iconic passage for vessels transiting from south to north. The presence of the fish farm will degrade the area as a location for recreational sailing;
• The development will damage an important sheltered dive site and wildlife tourism;
• The proposal will restrict access to the beach at Port na Morachd used for picnics and boat trips;
• The area will loose its unspoilt qualities and its attraction for kayaking and swimming;
• The Scottish Canoe Association objects on the grounds that the development will impede navigation and contribute to pollution to the detriment of the recreational resource and the tourism potential of this scenic location.
Comment: It is for Members to weigh the balance between the economic and employment advantages of the development against any adverse consequence which the presence of the development might have for established tourism related employment. Although the development will have localised impacts, these would be offset in part by the loss of existing adverse effects as a consequence of the removal of the existing site. There is no definitive research which leads to the conclusion that the presence of fish farms in Scottish waters has thus far proven to be an acknowledged deterrent to tourism, although given the importance of scenery as a tourism resource in Argyll & Bute it is to be expected that inappropriately located sites may deter visits by persons sensitive to the presence of such activities. SNH have not objected on the grounds that the development would be prejudicial to the landscape and associ ated recreational qualities of the area.
Objections in respect of navigation interests
• The development poses an unwelcome impediment to navigation given that Seil
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Sound is already a difficult passage constrained by numerous hazards and a strong tide.
• Sailing to windward through the channel is challenging and the site will make this impossible in some circumstances other than under power. Not all boats have engines and to use them unnecessarily is wasteful.
• An unmarked rock at the entrance to the sound causes yachts to give it a wide berth.
• The buoyed area will be so large that it will effectively halve the width of the entrance to the Sound making navigation difficult for the less experienced.
Comment: Issues relating to navigation would be considered by Marine Scotland as part of the Marine Licence required for the deployment of equipment in the water. As this is a separate regulatory regime, technical matters relating to navigation are not material planning considerations as such, although to the extent that they might have consequences for the tourism and recreational potential of the area they have an indirect bearing on the acceptability of the development. Whilst the seabed area of the application site is extensive (in order to contain the limits of the mooring arrangements) the surface equipment and the buoys around that equipment present much less of an obstruction to navigation, particularly as the Northern Lighthouse Board do not require the outer anchor points to be marked by buoys. There is a requirement for workboats and larger well-boats to be able to access the site for servicing purposes. Although there is some narrowing of the sound as a result of the equipment, the width of the channel is still at least 420 metres at its narrowest point. It should be borne in mind that any north-south transiting boat traffic would have to negotiate the much narrower Cuan Sound between Seil and the Isle of Luing.
Objections is relation to the principle of marine salmon farming
• The farming of fish in cages is a form of ‘battery farming’ which is environmentally irresponsible and unethical in terms of animal welfare, and which devalues the scenic landscapes within which it is situated;
• Fish farm pose highly destructive effects upon both their immediate and wider environments;
• They are not a solution to over-fishing as small fish are taken to produce food for farmed fish and the fish produced are not fit for human consumption due to contamination with chemicals;
• Underwater organisms are part of a finely balanced ecosystem which are fatally threatened by pollution associated with fish farming;
• There is an urgent need for world-wide standards to control fish farm escapes in the interests of maintaining wild fish stocks;
• The economic benefits of fish farming are overstated, particularly given the largely foreign ownership of companies (in this case Polish). Shameless profiteering should not be allowed to go ahead against the interests of the environment.
Comment: Consideration of the merits of this application requires to be confined to the site specific circumstances of the case. Whilst there are those who regard marine fish farming as being an unsustainable and environmentally harmful form of development as
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a matter of principle, it is a legitimate form of development supported by the Scottish Government who have targets for the development of the industry as a growth sector in the national economy and as valued source of employment within economically deprived rural areas of the country.
Suggested matters to be addressed by conditions in the event permission is granted
• Should permission be given, conditions should be imposed to require double netting, no use of seal scarers, no shooting of seals, no increase in biomass, low visibility equipment, a requirement to keep the site ‘clean’, and controls over lighting.
Comment: Whilst control over deployment of ADD’s, appearance of equipment and lighting are capable of being controlled by way of planning condition, matters controlled by other bodies such as biomass (SEPA) and seal shooting (Scottish Government) are not matters which could be the subject of competent planning conditions.
NOTE: Committee Members, the applicant, agent and any other interested party should note that the consultation responses and letters of representation referred to in this report, have been summarised and that the full consultation response or letter of representations are available on request. It should also be noted that the associated drawings, application forms, consultations, other correspondence and all letters of representations are available for viewing on the Council web site at www.argyll-bute.gov.uk
(G) SUPPORTING INFORMATION
Has the application been the subject of:
(i) Environmental Statement: No – the development has been the subject of a negative EIA screening opinion having regard to the views of consultees and the presence of the existing farm which is to be removed in the event that this development proceeds
(ii) An appropriate assessment under the Conservation (Natural Habitats) Regulations Yes – this form Appendix B 1994: to this report.
(iii) A design or design/access statement: No
(iv) A report on the impact of the proposed Yes – Site and development eg. Retail impact, transport Hydrographic Report, and impact, noise impact, flood risk, drainage Chemotherpeutant impact etc: Modelling for bath and in- feed treatments.
(H) PLANNING OBLIGATIONS
Is a Section 75 agreement required: No
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(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: No
(J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application
(i) List of all Development Plan Policy considerations taken into account in assessment of the application.
‘Argyll and Bute Structure Plan’ 2002
STRAT DC 5 – Development in Sensitive Countryside
STRAT DC 7 – Nature Conservation and Development Control
STRAT DC 8 – Landscape and Development Control
‘Argyll and Bute Local Plan’ 2009
LP ENV 1 – Impact on the General Environment
LP ENV 2 – Impact on Biodiversity
LP ENV 6 – Impact on Habitats and Species
LP ENV 10 – Impact on Areas of Panoramic Quality (APQs)
LP ENV 12 – Water Quality and Environment
LP ENV 19 – Development setting, layout and design
LP CST 2 – Coastal Development on the Undeveloped Coast
LP AQUA 1 – Shell Fish and Fin Fish Farming
Expresses general support for fish farming subject to there being no significant adverse effect on a range of specified considerations; those relevant in this instance being:
1. Communities, settlements and their settings; 2. Landscape character, scenic quality and visual amenity; 4. National Scenic Areas and Areas of Panoramic Quality; 5. Statutorily protected nature conservation sites, habitats or species, including priority species and important seabird colonies along with wild fish populations; 6. Navigational interests 8. Sites of historic or archaeological interest and their settings 9. Recreational interests 11. Existing aquaculture sites 12. Water quality
In the case of marine fish farming this support is further conditional on the proposals
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being consistent with the other policies of the Development Plan and Scottish Executive Strategic Framework Guidelines.
Appendix A – Sustainable Siting and Design Principles
(ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 4/2009.
Scottish Planning Policy (2010)
Circular 6/1995 ‘European Protected Species, Development Sites and the Planning System’ and revised Scottish Government Guidance June 2000
Circular 1/2007 ‘Planning Controls for Marine Fish Farming’
Scottish Executive – ‘Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters’ (2003 and updated June 2009 and December 2012)
‘A Fresh Start – the Renewed Strategic Framework for Scottish Aquaculture’ ( 2009)
‘Guidance on Landscape/Seascape Capacity for Aquaculture’ (SNH 2008)
‘Siting & Design of Marine Aquaculture Developments in the Landscape’ (SNH 2011)
‘Argyll & Firth Of Clyde Landscape Character Assessment’ (SNH 1996)
‘Argyll & Bute Local Biodiversity Action Plan’ Argyll & Bute Council
(K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: Yes
(L) Has the application been the subject of statutory pre-application consultation (PAC): No
(M) Has a sustainability check list been submitted: No
(N) Does the Council have an interest in the site: No
(O) Requirement for a hearing (PAN41 or other): Yes - it is recommended that a pre- determination hearing be convened in response to the number of representations received from third parties and the complexity of the issues raised.
(P) Assessment and summary of determining issues and material considerations
The proposal seeks permission for the installation of a marine finfish development of 12 No. 100m circumference (32m diameter) cages and a feed/service barge to be utilised for the production of farmed salmon.
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The application site is located to the eastern side of Seil Sound close inshore to the coast of the Degnish peninsula which also forms the north coast of Loch Melfort. It is situated to the east of the small island of Torsa which lies to the east of Cuan Sound off the north-east coast of the Isle of Luing.
The site lies off an area of remote, largely inaccessible and uninhabited land, where it would be most readily experienced from boat traffic negotiating the Sound, or at a distance from coastal properties south of Balvicar on the Isle of Seil. The site currently benefits from a Crown Estate shellfish lease for mussel rafts, although it is not equipped for production. The nearest fin fish site is operated by the applicants some 900m to the north at Ardmaddy. This comprises a block of steel cages which it is proposed to remove should this enlarged and more modern facility be consented. The proposal therefore constitutes a relocation which also involves an increase in licenced peak biomass from 1,300 to 2,500 tonnes. There are no other finfish farms in Seil Sound, the nearest sites being well removed within Loch Melfort and around the coast of Shuna to the south.
The proposal when submitted in 2011 prompted significant public objection in relation to the anticipated pollution effects of the development and the associated consequences for marine habitats and species. Pollution control in respect of marine fish farm developments is exercised by the Scottish Environment Protection Agency (SEPA) through the Controlled Activities Regulations (CAR licence) rather than by the Council. Planning Authorities are cautioned in government advice against attempting to duplicate other regulatory regimes, so other than pollution consequences for wild fish (which are not subject to SEPA control), the remaining pollution effects of this development are not material considerations for the planning application process. Likewise it is SEPA who consent permitted biomass to be held at the site and not the Council. With this situation in mind, the applicants agreed to the suggestion from officers that in this particular case it would be appropriate for this planning application to be held in abeyance pending the submission and determination of a CAR licence application by SEPA, so that issues surrounding pollution could be addressed in the first instance, without leading to inappropriate demand from third parties for these to be addressed as part of the determination of this planning application.
In the event, a CAR licence application was pursued, and despite third party opposition prompting consideration of the matter by Scottish Ministers, no intervention on their part took place and SEPA proceeded to issue a CAR licence in respect of this 2,500 tonne site towards the end of 2012. Subsequent to that, the determination of the planning application is now being pursued.
The site lies outwith but adjacent to the Firth of Lorn Special Area of Conservation (SAC), the closest point of which lies at Cuan Sound which is 1.8km away. Where a development proposal is not connected with the management of a Natura site for nature conservation, is likely to have a significant effect on the site (either alone or in combination with other plans or projects), or effects are unknown, then the ‘competent authority’ assessing the merits of a development proposal (in this case the Planning Authority) is required to carry out an ‘appropriate assessment’ in order to evaluate anticipated effects on the conservation objectives of the designated site. This applies equally to developments located outwith designations which have the potential to impact upon qualifying interests within the designations, as it does to those developments proposed within designated areas. In such circumstances, only when it is concluded ‘beyond reasonable scientific doubt’ that the development under consideration will not adversely affect the integrity of the designation, may permission be granted. In all other circumstances permission must be refused (other than in the specifically excepted cases where no alternatives exist, or there are imperative reasons of overriding public interest for development to proceed).
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SEPA as ‘competent authority’ in respect of the CAR licence process conducted their own ‘appropriate assessment’ prior to the granting of the licence for this site, which concluded that the proposal would not compromise the nearby SAC designation. Although SEPA’s assessment is a matter of record, as the planning process commenced prior to SEPA’s consideration of the matter, it remains incumbent upon the Planning Authority to conduct its own ‘appropriate assessment’ as part of the planning application determination process. This can be found at Appendix B to this report. It draws on SEPA’s conclusions (which are annexed to the appendix) as well as advice provided by Scottish Natural Heritage. This concludes that impacts from solids flux, sea lice treatments and nutrients are calculable, and having regard to modelling results and accepted environmental standards, the development proposed will not adversely affect the integrity of the SAC in light of its conservation objectives.
Neither SNH, SEPA, Marine Scotland, nor the District Salmon Fishery Board have raised objections to the proposal. Objections have however been lodged by the Clyde Fishermen’s Association, the Scottish Wildlife Trust, and adjacent Community Council’s
Scottish Planning Policy indicates the national importance of aquaculture in the context of rural areas and that fish farming should be supported in appropriate locations, subject to environmental considerations being assessed. Carrying capacity, landscape, natural environment, historic environment and potential for conflict with other marine users, including fishing and recreational interests, and economic factors will be material considerations in assessing acceptability. Planning Authorities are cautioned not to duplicate controls exercised by SEPA and Marine Scotland in their assessment of proposals.
Government policy is to support the expansion of marine fish farming where it can take place in environmental sustainable locations, where it does not exceed the carrying capacity of the water body within which it is to be located and where it does not give rise to significant adverse effects upon nature conservation, wild fish, historic environment or other commercial or recreational water users. The intention of this proposal is to enable the replacement of a first generation fish farm with more modern equipment in a more hydrographically favourable location, whilst also taking the opportunity to expand capacity. Despite the increase in biomass, the surface area of the cages would reduce marginally, although the less compact layout of circular rather than square cages would lead to an overall increase in the extent of surface footprint.
It has already been demonstrated to SEPA’s satisfaction that the development can operate without compromising recognised water quality standards and that discharges from the site will not affect the integrity of nearby European protected habitats. The location of the site between the largely unpopulated coasts of Degnish and Torsa are such that it will not exert influence over the land to any degree beyond that already associated with the nearby site which it is intended to replace. Both sites lie within the same local plan designated Area of Panoramic Quality. Sensitive receptors on land on the Seil coast to the north would benefit from the intended relocation of the site southwards at increased separation. The site would however be relocated to a narrower section of the Sound, which would bring those navigating the Sound closer to the equipment. However the proposal would reduce the number of consented aquaculture sites from one shellfish and one finfish site to the single site proposed, so any increased visual impact would be offset by this reduction in the number of sites. Whilst the width of the navigational channel will be reduced, at 420m this would not be to the extent that it would frustrate navigation. This aspect would be addressed separately by the Marine Licence process.
Significant representation against the proposal has been received, primarily on grounds
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that the development would increase pollution and pose a threat to protected habitats and species. The extent and complexity of the issues raised are such as to warrant a local hearing prior to the determination of the application.
(Q) Is the proposal consistent with the Development Plan: Yes
(R) Reasons why Planning Permission or Planning Permission in Principle Should be Granted:
The proposal involves the establishment of a new marine finfish farm, which would entail the de-equipping of an established farm to the north of the site and the relinquishment of the lease, and which would supersede an undeveloped but consented shellfish farm within the application site. It would maintain the number of finfish farms in Seil Sound at a single site. Whilst the development would occupy a narrower section of the Sound and would occupy a larger overall footprint, other than for the addition of a feed barge, the aggregate surface equipment area would remain similar to that at the existing site. The landscape and visual consequences of the development relative to the existing position are considered acceptable, whilst the separation from sensitive receptors avoids unacceptable amenity conflicts. Navigation of the Sound will remain unimpeded and recreational interests will not be seriously prejudiced. The pollution consequences of the development in combination with other fish farm developments upon the protected habitats of the Firth of Lorn SAC have been assessed by means of ‘appropriate assessment’ and it has been determined that this proposal will not adversely affect the integrity of this European marine designation. The proposal satisfies the provisions of the development plan and there are no other material considerations, including matters raised by consultees and third parties, which would outweigh the presumption in favour of development established by the plan.
(S) Reasoned justification for a departure to the provisions of the Development Plan
Not applicable
(T) Need for notification to Scottish Ministers or Historic Scotland: No
Author of Report: Richard Kerr Date: 29th February 2013
Angus Gilmour Head of Planning and Regulatory Services
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CONDITIONS AND REASONS RELATIVE TO APPLICATION 12/00904//MFF
1. The development hereby permitted shall not be carried out other than wholly in accordance with the following plans and details unless previously approved in writing by the Planning Authority:
• Application Form dated 13.06.11; • Plan 1 of 9 – current and proposed site locations and layout; • Plan 2 of 9 – location plan 1:10,000; • Plan 3 of 9 – location plan 1:25,000; • Plan 4 of 9 – Admiralty chart indicating mooring containment area; • Plan 5 of 9 – site layout plan; • Plan 6 of 9 – cage sections; • Plan 7 of 9 – net specifications; • Plan 8 of 9 – feed barge specifications (amended 18.12.12); • Plan 9 of 9 – feed barge appearance (amended 18.12.12).
Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details.
2. The stocking of the farm hereby approved with fish shall not take place until the fish pens walkways, associated structures and moorings have been removed from the existing site at Ardmaddy North (0.9km north of the consented site) and evidence has been presented to the Planning Authority that the existing Crown Estate lease has been relinquished in order to prevent subsequent re-equipping of that site.
Reason: Consent for this development is granted solely on the basis that this development will replace the existing operation. Occupation of this site in association with the existing site would produce unacceptable cumulative impacts as a result of the presence and operation of multiple sites in inappropriately close proximity which would exceed the carrying capacity of the receiving environment.
3. In the event that the development or any associated equipment approved by this permission ceases to be in operational use for a period exceeding three years, the equipment shall be wholly removed from the site thereafter unless otherwise agreed in writing by the Planning Authority.
Reason: In the interest of visual amenity and to ensure that redundant development does not sterilise capacity for future development within the same water body.
4. In the event of equipment falling into disrepair or becoming damaged, adrift, stranded, abandoned or sunk in such a manner as to cause an obstruction or danger to navigation, the developer shall carry out or make suitable arrangements for the carrying out of all measures necessary for lighting, buoying, raising, repairing, moving or destroying, as appropriate, the whole or any part of the equipment.
Reason: In the interest of visual amenity.
5. All lighting above the water surface and not required for safe navigation purposes should be directed downwards by shielding and be extinguished when not required for the purpose for which it is installed on the site.
Reason: In the interest of visual amenity .
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6. The finished surfaces of all equipment above the water surface including the feed barge and surface floats and buoys associated with the development hereby permitted (excluding those required to comply with navigational requirements) shall be non- reflective and finished in a dark recessive colour in accordance with colour schemes to be agreed in advance in writing by the Planning Authority (by way of BS numbers or manufacturer’s specifications) unless otherwise agreed in advance in writing by the Planning Authority.
Reason: In the interest of visual amenity.
7. No deployment of Acoustic Deterrent Devices shall be permitted at the site unless the model intended for use and the means of its use have been submitted to and approved in writing by the Planning Authority, following consultation with Scottish Natural Heritage. Thereafter deployment shall only take place in accordance with the duly approved details unless any subsequent variation thereof is agreed in writing by the Planning Authority.
Reason: In the interests of nature conservation.
NOTES TO APPLICANT
• This permission shall only last for a period of three years from the date of this decision notice unless the development is started within that period.
• In order to comply with Sections 27A(1) of the Town and Country Planning (Scotland) Act 1997, prior to works commencing on site it is the responsibility of the developer to complete and submit the attached ‘Notice of Initiation of Development’ to the Planning Authority specifying the date on which the development will start. Failure to comply with this requirement constitutes a breach of planning control under Section 123(1) of the Act.
• In order to comply with Section 27B(1) of the Town and Country Planning (Scotland) Act 1997 it is the responsibility of the developer to submit the attached ‘Notice of Completion’ to the Planning Authority.
• In terms of condition 1 above, the council can approve minor variations to the approved plans in terms of Section 64 of the Town and Country Planning (Scotland) Act 1997 although no variations should be undertaken without obtaining the prior written approval of the Planning Authority. If you wish to seek any minor variation of the application, an application for a non material amendment (NMA) should be made in writing to Planning Services, Whitegates Office, Whitegates Road Lochgilphead, PA31 8SY which should list all the proposed changes, enclosing a copy of a plan(s) detailing these changes together with a copy of the original approved plans. Any amendments deemed by the Council to be material, would require the submission of a further application for planning permission.
• The applicant should have regard to the navigational marking requirements of the Northern Lighthouse Board as set out in their consultation response.
• The deployment of Acoustic Deterrent Devices at this site may be subject to a requirement for a licence to be obtained in advance from Scottish Natural Heritage in respect of disturbance to cetaceans, in addition to the requirements of condition 7
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above. Early consultation with SNH over the matter of the prospective deployment of ADD’s is recommended.
APPENDIX A – RELATIVE TO APPLICATION NUMBER: 09/00905/MFF
PLANNING LAND USE AND POLICY ASSESSMENT
A. Location, Nature and Design of Proposed Development
The applicant in this case is Lakeland Marine Farms Ltd (part of the Meridian Group) who currently operate a number of finfish farming sites across Argyll including an existing site at Ardmaddy (referred to as Ardmaddy North for the purposes of this application). That site is a first generation farm comprising 18 No. 10m deep 24m x 24m square metal cages, projecting 1.4m above the surface, with bird exclusion nets and several sheds mounted on the walkway structures, but without a feed barge. It provides an aggregate cage surface area of 10,368m 2 within an overall occupied surface area of 13,440m 2, secured within a seabed a mooring area of 145,000m2. It has a licenced maximum biomass of 1,300 tonnes. The applicants seek to replace that equipment whilst at the same time expanding the productive capacity of the farm, and in so doing have identified a hydrographically more favourable site 900m to the south, which would lend itself to the increased biomass proposed.
The proposed site (referred to as Ardmaddy South for the purposes of this application) lies on the same side of the Sound some 900m to the south of the location of the current equipment. The site is located off the west coast of the Deignish peninsula at Port na Morachd, about 1km to the north of Deignish Point and on the opposite side of the Sound to the small island of Torsa. The proposal is to equip the site with 12 No. 100m circumference circular cages grouped together in a 6 x 2 rectangular mooring grid, producing a slightly reduced aggregate area occupied by surface equipment that at Ardmaddy North at 9,549m 2, within a larger 179,800m 2 mooring area (580m x 310m). The cages would be fitted with a centrally supported top net structure giving an overall maximum height of 2.6m at the cage centre point. The site would have a maximum biomass of 2,500 tonnes - 1,200 tonnes greater than the existing site at Ardmaddy North. The main difference in the appearance of the site will be accounted for by its less compact format due to the bigger gaps between circular cages, and the addition of a feed barge at the north end of the cage group. It will therefore occupy a larger area of water (cage grid within a buoyed support structure of 100m x 300m), despite the fact that the surface area of the equipment within this overall area will be less than that of the pens at the present site.
The application site already benefits from a Crown Estate lease for a shellfish farm comprising 6 No. 10m 2 mussel rafts within a 55,000m 2 mooring area, although the site is not currently equipped for production. It is intended that the proposal will supersede the shellfish site and that the lease for the Ardmaddy North site would be relinquished and the equipment removed, in the event that this larger replacement farm at Ardmaddy South is consented.
The proposed cages comprise circular polyethelyene flotation rings approx.1.2m high above the waterline with a diameter of 32m, from which 15m deep nets will be suspended. The cages will be fitted with a ‘hamster wheel’ top net support 2.6m high which will enable the fitting of 25mm mesh nets over the cages for the purpose of excluding pisciverous birds. The nets are fitted with false bottoms (seal blinds) to deter predator attacks from below, and are held in tension, again to resist predation. The cages will be secured in place by a rectangular 100m x 300m mooring grid with mooring lines and rock anchors used to secure the position of the grid relative to the seabed. The site will be aligned SW - NE parallel to, and close inshore to, the mainland
Page 22 coast. The feed barge originally proposed was 18m x 26m in area although this has since been reduced by way of amended plans showing a much smaller barge 14.0m x 10.5m in area and 5.3m in height maximum, dependent upon the quantity of feed held. The barge comprises four silos, a generator, maintenance and crew accommodation. It will be finished in a recessive colour with generator noise only audible at close quarters. The site will be staffed by 3 to 4 full-time employees plus 2 part-time staff and will safeguard the jobs currently associated with Ardmaddy North. Deliveries to the site will be by sea from Lakeland’s existing shore base at Loch Craignish. Personnel transfers will take place by boat from a staff facility at Croabh Haven. Underwater lighting would be used to control maturation and maximise growth December to May every second year with 2 No, 1,000w lights being used 5m beneath each cage. These would be powered by the feed barge generator and would produce a surface glow only visible at close quarters or from elevated vantage points. Other lighting on the site, with the exception of navigational requirements, would be restricted to essential requirements so as to avoid unnecessary illumination on the site.
The section of the Sound to which the site is to be relocated is narrower than that occupied by the equipment at Ardmaddy north being some 700m wide at this point and narrowing off to the south due to the presence of the island of Torsa. The nearest fish farm site is that at Ardmaddy North (to be relinquished) with the next nearest sites either being within Loch Melfort or off the north coast of the island of Shuna, some 5km to the south. Seil Sound is ‘unclassified water’ for the purpose of Marine Scotland’s Locational Guidelines for fish farms in marine waters, as it is a complex open water body which does not suit the modelling used to inform the guidelines (which relate more to sealochs which are most susceptible to cumulative impacts). In view of this the applicant has undertaken nutrient enrichment modelling which has been accepted by Marine Scotland and by SEPA in their ‘appropriate assessment, which in turn informs the conclusions of the Councils own assessment.
The site lies within Management Area 16d (Seil Sound to Loch Craignish). There is no Area Management Agreement in place for this location at the moment due to the decision of wild fish interests to withdraw from the former Lower Lorn AMA. The applicants are, however, part of the Lower Lorn Farm Management Agreeement with Kames Fish Farm which ensures synchronous stocking and treatments between the two companies actively farming in this area. The intended peak biomass (fish tonnage) for the overall site is 2,500 tonnes. The stocking density would be 17.4kg per m 3 max. The production cycle of the farm would be 22 months with 2 months left fallow to assist in benthic (sea bed) recovery.
The site would be operated in compliance with the Scottish Salmon Producers Organisation’s ‘Code of Good Practice Guidelines for Scottish Finfish Aquaculture’. This sets out more than 300 main specific compliance points which cover all aspects of finfish good practice including:
• Fish Health – good husbandry and harvesting operations; • Protecting the environment – including sea lice management and containment standards; • Welfare and husbandry – breeding and stocking density; • Detailed annexes giving further technical guidance on good practice, including the National Lice Treatment Strategy, Integrated Sea Lice Management, Containment, and a Veterinary Health Plan.
The applicants have provided details of their Emergency Mortality Removal and Escapes Contingency procedures, manufacturers’ site specific attestations for equipment, nets and moorings, their Veterinary Health and Biosecurity Plan and their Predator Risk Assessment and Predator Control Plan. With regard to predator control,
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it is noted that the ES states that Acoustic Deterrent Devices (ADDs) would only be deployed in circumstances where the site becomes subject to attempted predation. As a last resort in the event of persistent rogue seal activity, the shooting of seals may take place in accordance with a Scottish Government licence already held by the company.
B. Natural Environment - Fresh Water, Marine Environment and Biodiversity.
The provisions of Policies STRAT DC 7, LP ENV 2 and LP ENV 6 all seek to resist development which is considered likely to result in a significant adverse impact upon internationally, nationally or locally important habitats and/or species.
The application site is not located within any European or national nature conservation designations. Whist the proposal lies outwith the Firth of Lorn Special Area of Conservation (SAC) it is within potential influencing distance of the SAC, the nearest point of which is some 2km away at Cuan Sound, and for that reason a Habitats Regulations ‘appropriate assessment’ has been carried out in respect of qualifying interests of this European marine site. The Sound is also frequented by species of nature conservation interest including seals and wild salmonids, for which development of the type proposed could have consequences in terms of displacement or deterrence. Salmon and Sea Trout are vulnerable to interaction with farmed fish and both a UK BAP and the A&B LBAP species and included in the Argyll & Bute Local Biodiversity Action Plan. The Sound also host to white cluster anemone, which is a Priority Marine Feature.
Seabed (Benthic) Impacts:
The development will affect seabed conditions as a consequence of the deposition of organic matter in the form of faeces. Furthermore, although the industry has made advances in the reduction of waste food as a result of more sophisticated feeding regimes, waste food also contributes to seabed deposition. This can take the form of localised smothering of the seabed as well as more distant deposition arising from the propagation of waste matter from the site. The quantity and the extent of deposition are influenced by the tonnage of fish held, hydrographic and bathymetric conditions. Seabed impacts are regulated separately by SEPA via the CAR licence process, which determines maximum biomass with regard to the carrying capacity of the particular site.
The applicants have provided a benthic survey, a visual assessment and a modelling assessment in support of their proposal, all of which have been considered by SEPA as part of their CAR licence application and which have helped inform SEPA’s conclusions in respect of their ‘appropriate assessment’. The seabed below the proposed site comprises firm mud, shell and gravel which supports a diverse range of mollusc, crustacean and echinoderm. There are no specifically designated habitats below or in the immediate vicinity of the site. Modelling has been used to predict a site specific Allowable Zone of Effect (AZE) in order to demonstrate compliance with SEPA’s requirements. This indicates that there will be localised enrichment with high dispersal at what is regarded to be a moderately flushed site. SEPA has accepted this conclusion along with the fact that there will be low cumulative impact as the next nearest site is 2.5km distant. The CAR licence which was issued at the end of 2012 addresses the discharge consequences of the development in terms of smothering as well as chemical treatments and cumulative nutrient enrichment.
SNH and SEPA are both content with the benthic surveys undertaken by the applicant and neither have objections to the proposal on the grounds of unacceptable benthic impacts.
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Water Quality Impacts:
Enrichment of water by nutrients released from salmon farms can cause an accelerated growth of algae and higher forms of plant life to produce an undesirable disturbance to the balance of organisms and the quality of water.
This site is located at the SE entrance to Seil Sound which is subject to tidal currents producing a moderately flushed site, and modelling indicates that waste dispersal will be into the deeper water of the Sound as well as to Loch Melfort and Shuna Sound. Estimated nutrient enrichment is well below the threshold of 50% above the OSPAR and UTAG reference levels, and consented sea lice treatments have been set in the CAR licence for the site at a level which will not breach SEPA’s Environmental Quality Standards. Whilst localised impacts are anticipated from particulate and dissolved wastes, modelling results indicate that these, when considered cumulatively with other consented sites, will not result in a significant deterioration in the quality of the receiving water body; a position accepted by SEPA in the issuing of a CAR licence for the biomass sought by the applicants.
Neither Marine Scotland Science nor SEPA have raised objection to the proposal in respect of the predicted impact of the development upon water quality.
Interaction with Predators:
Salmon farm predators are generally piscivorous birds and seals, with the latter tending to be the most frequently encountered predators on marine farms in Scotland. The presence of sea cages may attract higher concentrations of predators to the locality of the site, although good husbandry and hygiene procedures will help to reduce the attraction of predators. Tensioned netting on fish cages prevents and deters both seals and diving bird attacks, although regular removal of mortalities from the bottom of the nets and regular maintenance of the nets to maintain their integrity is necessary to avoid attempts at predation. Top nets are to be installed on the cages to avoid predation by birds from above the waterline. Bird nets require to be maintained to a high standard and properly tensioned eliminate the opportunity for birds to become entangled or to be able to enter the cage. The fish cages themselves are to be manufactured to current industry standards, with a net specification, tensioning arrangements, false bottoms and an installation, inspection and maintenance regime to meet the SSPO ‘Code of Good Practice’ requirements. It is clearly in the operator’s interest to ensure that equipment is specified and maintained in a manner to ensure containment of the farmed fish. Site specific equipment attestations have been supplied to confirm that, in the respective manufacturer’s opinions, the equipment intended for use on this site is suitable and sufficiently durable to be deployed having regard to the characteristics of in the particular marine environment proposed.
The ES does not identify any major colonies of predators in the vicinity of the application site, although there are recorded haul outs within 2km at Cuan Sound and Scoul Eilean. The Environmental Statement concludes that proposed use of good husbandry (mortality and moribund fish removal) and hygiene practices based on experience at other sites, coupled with the use of tensioned nets and top nets will be sufficient to deter predators at the proposed site. In the event of persistent predator activity, the applicants wish to maintain that option to deploy Acoustic Deterrent Devices (ADD’s) to scare away seals in order to avoid to resorting to the shooting of seals. Technology has improved in recent years with devices available which are more
Page 25 effective than previous systems and are more localised and targeted in their impact. SNH have asked that deployment of ADD’s be subject to their approval via planning condition. Only in extreme circumstances would resort be made to the shooting of seals under government licence. The applicants already hold a Seal Management Licence for their 9 sites on the west coast, including Ardmaddy North, to which they would request this proposed site by way of an addition in the event that planning permission is granted. During 2012 one seal was shot in connection with the applicant’s farm at Ardmaddy North.
Scottish Natural Heritage has not raised objection to the proposal on the grounds of unacceptable consequences for potential predators or impacts on non-target wildlife.
Interaction with Wild Salmonids:
Farming of salmon in the marine environment can give rise to well-known consequences for wild fish as a result of disease transmission, sea lice propagation and escapes which can lead to competition and inter-breeding, with consequences for the genetic dilution of native wild stocks. The potential for escapes (as with predator control) can be reduced by having an equipment specification determined by site specific wave and climate analysis so as to ensure that it is fit for purpose. An associated inspection and maintenance regime is then required to ensure on-going containment integrity. Predator control plans, and escapes contingency plans, as submitted by the applicant, are also important elements in risk management.
Although containment risks can be managed, they cannot however be eradicated and there remains a residual risk that an unforeseen event can propagate escaped farmed fish in large numbers into the uncontrolled marine environment. Escapes of farmed stock are generally low, but can occur through equipment failure, predation, operator error, severe weather or foul play. By adherence to the SSPO ‘Code of Good Practice Guidelines’ the applicant seeks to minimise this residual risk as far as is practicable. Likewise, via good husbandry practices, regular inspection and the administration of medicines in accordance with veterinary health plans, outbreaks of disease which could have consequences for wild fish can be managed.
The most intractable issue influencing the interaction between farmed salmon and wild fish species is that of sea lice transmission. Farmed fish are routinely hosts to parasitic sea lice, the numbers of which require to be controlled in order to assure the health of farmed fish and to avoid lice propagation into surrounding waters. Wild salmon can be exposed to sea lice from fish farms close to salmon rivers during their migration periods, whilst sea trout tend to remain in coastal waters throughout the year, so are potentially at greater risk. In this case there are no major wild salmon fisheries within 15km of the site.
The applicant proposes to control sea lice in accordance with current industry practice, via the use of in-feed treatments and well-boat administered bath treatments, whilst adopting good management practices such as single year stocking and synchronous stocking, fallowing and lice treatment with other sites within the Lower Lorn Farm Management Agreement. All sea lice bath treatments are intended to be carried out on board well-boats (rather than the more traditional method of net shallowing) which is a superior method, in terms of control over exposure time and dosage to ensure the effectiveness of those treatments. It also enables more than 50% reduction in the use of chemotherapeutants over treatment administered within cages. The applicants are also trialling the use of wrasse as a means of biological control over sea lice hosted on farmed salmon, which again presents opportunity to reduce the administration of chemical controls. .
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However effective the control measures are in practice, it is an inevitable consequence of holding fish in such quantities that significant numbers of sea lice will be propagated from the site. How these are dispersed will depend on local factors such as wind direction and residual current. The distribution of farm derived lice in the marine environment is not well understood although it is known that in favourable conditions they can travel considerable distances from source.
In addition to sea lice propagation, failure of containment can lead to escapes which pose a threat to wild fish due to competition or through breeding. The applicants consider that their tensioned net systems are appropriately specified so as to be fit for purpose at the site and that they are accompanied by appropriate management measures and predator control arrangements to minimise the prospect of escape events. None of the applicant’s fish farm sites in Argyll have to date been the subject of mass escapes.
The conclusion of the applicant’s supporting information is that the site will not prejudice wild fish interests. The applicants have stated that they have not had sea lice problems with the existing site at Ardmaddy North and sea lice treatment already consented by SEPA is suitable to allow efficacious treatment of lice populations at this enlarged site in accordance with recognised standards.
Neither Marine Scotland nor SNH have objected to the proposal on the grounds of the threat posed to wild salmonids. The District Salmon Fishery Board have not objected subject to removal of the existing site, but have expressed their preference for the site to operate on the basis of reduced biomass in order for effective treatment to be demonstrated. Given the capital investment in an enlarged facility such as this, a conditional obligation for under-stocking would not be a reasonable planning requirement.
Impact upon Species and Habitats of Nature Conservation Importance:
No species or habitats of nature conservation importance were identified by the applicant’s submitted seabed survey within the predicted depositional footprint of the proposed farm. The presence of white cluster anemone (a Priority Marine Feature) 150m north of SPA’s Allowable Zone of Effect (AZE) has been pointed out by the Scottish Wildlife Trust. This has been accounted for by SNH in their response to SEPA’s CAR licence consultation, with the view being expressed that whilst localised changes to the structure of the colony may occur as a result of the operation of the farm, these are unlikely to affect the long-term viability of the species at this location or its overall conservation status in the context of north Argyll.
There are no nature conservation designated sites (SSSI’s or SAC’s) in the immediate vicinity of the proposed farm, although it does lie within a Marine Consultation Area defined by Scottish Natural Heritage in view of the overall quality of the marine environment. The closest designated site is the Firth of Lorn SAC to the west of Cuan Sound and the Isle of Luing identified for its rocky reef habitat. The SAC covers open water to the west of Seil and Luing and waters around Scarba and to the north of Jura, but excludes the more enclosed waters of Seil Sound, Shuna Sound and Loch Melfort. A map of the designated area appears in the ‘appropriate assessment’ at Appendix B.
Covering an area of approx. 210km 2 the Firth of Lorn SAC has been designated for its rocky reef habitats which support an exceptional marine biodiversity, with associated communities and species which are amongst the most diverse in both the UK and Europe. Conservation objectives for the SAC are to avoid deterioration in the qualifying interest (rocky reefs) thereby ensuring that the integrity of the designation is maintained. Although at a distance from the designated SAC, there may be potential
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for the proposed development to affect the designated area by means of the deposition of organic waste and by chemotherapeutants transported into the designated area by tidal currents. The proposed fish farm has the potential to affect qualifying interests in a number of ways. Firstly, from smothering as a result of the transport and deposition of solids; secondly, due to toxicity from the exported residues of chemical treatments; and thirdly, from the cumulative impact of the development with other sites within influencing distance of the SAC.
Where a development has the potential to give rise to significant effects upon the qualifying interests of a European Natura designation, the ‘competent authority’ considering the merits of any development proposal within, or within influencing distance of, the designated area is required to undertake ‘appropriate assessment’, if it considers that it presents the possibility of significant environmental effects upon that designation. Where a likely significant effect is anticipated, development may only proceed if the ‘appropriate assessment’ concludes beyond ‘reasonable scientific doubt’ that the integrity of the SAC will not be compromised. In all other circumstances to satisfy the requirements of the Habitats Directive, permission must be refused (other than in the specifically excepted cases where no alternatives exist, or there are imperative reasons of overriding public interest for development to proceed).
Interaction between the site and the SAC designation in terms of the transport of organic waste and chemotherapeutants has been reviewed by SEPA by way of a Habitats regulations ‘appropriate assessment’ in association with their CAR licence process. An ‘appropriate assessment’ on behalf of the Planning Authority drawing heavily upon the conclusions reached by SEPA, can be found at Appendix B to this report. In reaching its own conclusions as set out in that appendix, the Council has consulted both with SEPA and SNH for their views on the matter. Dispersal modelling accepted by SEPA indicates that solids and in-feed chemical residues will be predominantly exported via Cuan Sound into a dispersive environment where additional amounts will not be such as to breach Environmental Quality Standards (EQS) set by SEPA, or to compromise the conservation objectives of the SAC.
The Planning Authority’s ‘appropriate assessment’ has considered the likely environmental effects upon habitats and species associated with the SAC and has concluded that the proposal both in isolation, and in combination with other consented sites, will not have an adverse effect on the integrity of the site, in the light of its conservation objectives.
Scottish Natural Heritage has not raised objection to the planning application or the SEPA CAR licence on the grounds of unacceptable consequences for marine mammals, otters, the priority marine feature ‘white cluster anemone’ or the qualifying reef habitat of the SAC
Conclusion
The proposal is considered consistent with Local Plan Policy LP AQUA 1 (5 and 12) and other relevant development plan policies insofar as it would not significantly prejudice water quality and associated biodiversity interests.
C. Landscape/Seascape Character
The application site lies inshore in a relatively remote location off the west facing coast of the Degnish peninsula. From the land the site would be visible from the west facing slopes above the coast, but there is no road access to this area, no overlooking habitation and little public access appears taken to this area other than for the path
Page 28 between Loch Melfort and Ardmaddy which is set well back from the coastline behind the high ground overlooking the site. The opposing coast is formed by the eastern side of the small island of Torsa. There is no habitation on the east facing coast of the island, and there are unlikely to be few sensitive receptors affected. The site would be visible, but at a distance in excess of 2km, from a handful of isolated properties to the north-west on the Isle of Seil, which can be found close to the coast and to the south of Balvicar. There will be some limited visibility from the land either side of the Cuan Ferry but remaining visibility from Luing would be from the largely unpopulated east coast, other than for long distance visibility, end on to the site, from Toberonochy at over 5km away. The existing site at Ardmaddy North lies closer to the closest properties south of Balvicar than the location of the proposed site, which lies at an increased distance from any habitation. Any disbenefit arising from the enlarged site, including the additional impact of a feed barge would be largely offset by the removal of the existing equipment closer to Seil. Both the existing fish farm at Ardmaddy North and the proposed site lie adjacent to areas designated as ‘sensitive countryside’ and ‘Areas of Panoramic Quality’ by the adopted local plan, so share the same development plan context.
The ‘Area of Panoramic Quality’ accords the locality a scenic designation of regional status. The provisions of Policies STRAT DC 8 and LP ENV 10 seek to resist development which is considered to have a significant adverse impact upon the key landscape characteristics of these designations. Both the mainland and the islands either side of Seil Sound are identified as falling within the ‘Craggy Coast and Islands’ landscape character type, identified by Scottish Natural Heritage as having a small scale diverse topography within a distinct seascape context which provides a unifying element. The more inaccessible sections of coast exhibit a sense of isolation and naturalness which is less apparent on the more inhabited stretches of coast. The APQ recognises the panoramic value of the seascape and the views to and from the islands.
The intended location lies close inshore and parallel to the coast, where it would benefit from a dark coloured and elevated landscape backdrop, whilst the equipment is low- lying and to be finished in a recessive colour. This meets with SNH good practice guidance on the location and design of marine aquaculture development. Most terrestrial receptors (roads, transport routes, frequented public locations) would be at a significant distance from the equipment which would not assume importance in its landscape setting when appreciated from such locations. The lack of access being routinely taken to the isolated stretch of coast on the mainland immediately above the site is such that there will be few receptors taking closer quarter views down into the equipment.
The primary effect upon the perception of the landscape/seascape of Seil Sound will be in terms of those transiting the Sound by boat. Seil Sound is a body of enclosed water which is frequented by recreational boat traffic and a recognised cruising route. Yachts, tour boats and kayaks currently pass the existing site at Ardmaddy North, so their experience of the Sound is already influenced by the presence of aquaculture equipment. Although the proposed site is larger in extent and the Sound is narrower in the vicinity of the proposed site, there will be a small reduction in the aggregate surface area of the equipment and the round cages proposed are less visually intrusive that the existing square cages, which form a more compromising block with less intervening water. Whilst a feed barge is proposed, and this is an additional element not present at Ardmaddy North, the applicants have reduced the scale of that proposed significantly in order to limit the impact of this structure. Feed barges are now an almost standard requirement in the servicing of modern marine fish farm operations and it would be unrealistic to expect a site of this nature not to include one. Provided that the model selected is finished in a recessive colour it will not be an unacceptable element of the development.
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The proposal would also remove the prospect of the existing shellfish lease being taken up for the siting of mussel rafts on the application site. The removal of the equipment form Ardmaddy North in favour of the proposed development would mean that there would still be one fish farm to be passed by boat traffic at the southern end of the Sound. Despite the revised location and the altered appearance of the equipment, there would be overall little change in the perception and the appreciation of landscape/seascape from the water, with aquaculture retaining a presence in the locality by way of a single finfish farm, well removed from the next closest aquaculture site, so that cumulative impact does not become unacceptable in landscape or visual terms.
Scottish Natural Heritage are of the opinion that the landscape and visual effects of the development will be localised. Whilst it has been suggested that the impact of the feed barge could be reduced by repositioning it to the southern end of the site, where it would benefit from screening by the higher part of the island of Torsa, the applicants do not consider this to be desirable operationally as their practice is to site barges on the less exposed ends of sites, where in the event of storm damage, the threat to the integrity of the cage group is less. The applicant’s response has been to downsize the scale of the intended barge in its originally proposed location as an alternative means of addressing this suggestion.
Conclusion
The proposal complies with Local Plan Policy LP AQUA 1 (2 and 4) and other relevant development plan policies insofar as it would not significantly prejudice landscape character, visual amenity or designated areas of scenic quality. In view of the absence of other aquaculture in the immediate locality, and the intention to remove equipment from the existing site at Ardmaddy North in the event that permission is granted, the development does not present any cumulative impact issues of concern.
D. Other Marine Users
The development of the proposed site would entail the relinquishment of the existing Crown Estate lease for the fish farm site at Ardmaddy North. This would release new ground for inshore creel fishing once the seabed has had opportunity to recover from the presence of an operational farm. The Sound is not used for trawling. Although the Clyde Fishermen’s Association has objected to the development their objections tend to be founded around the growth of the aquaculture sector in general and the perceived unsustainability of the industry rather than upon specific shortcomings associated with the location of the application site or the details of the proposal.
The proposed site is located in a narrower section of the Sound than the current site and the proposed mooring area extends further out into the Sound than the area which is the subject of the current Crown Estate shellfish lease area. Despite that, the equipment is to be located close inshore to the east of existing navigational and RYA cruising routes, which will ensure that the surface equipment and the associated moorings do not impinge upon access into and out of the south of the Sound by boat. Navigational implications of the development will be considered separately by Marine Scotland under the marine licencing procedure. It should be borne in mind that whilst the seabed foot print of the mooring area is extensive at 580m x 310m, around a third of the seaward end of the mooring lines will be on the seabed rising up to the cage mooring grid which is supported by riser buoys 8m out from the cages. Therefore navigation relatively close to the cage group is possible, and indeed the installation has been designed to afford sufficient draught for a large well boat to service the farm and for workboats to come alongside the cages.
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Conclusion
The proposal complies with Local Plan Policy LP AQUA 1 (6 and 11) and other relevant development plan policies insofar as it would not significantly prejudice navigation and the continued exploitation of traditional fishing ground.
E. Noise
Noise associated with the development will arise from the operation of workboats and other vessels associated with the fish farm, plus noise from the generator within the concrete feed barge. Given the absence of local habitation or other sensitive receptors, and the transient nature of other boat traffic, this will not present a problem in terms of the operation of the site. The applicants already utilise the type of feed barge intended to be employed at this site and experience of that in operation is such that it is evident that generator noise will not pose a threat to amenity.
F. Transport
As with the existing site at Ardmaddy North, there will be no need for access to the locality of the site by road. Servicing and deliveries will be undertaken by boat from the applicant’s existing shore base in Loch Craignish. Personnel will take access by small boat from an existing facility adjoining the marina at Craobh Haven. Stocking and harvesting of fish, and treatment of sea lice, will take place by larger vessels.
G. Conclusion
The proposal has given rise to considerable public objection. Concerns have been expressed by 3 rd parties in terms of pollution of the water environment, impact upon habitats and species, and in view of the presence of the equipment in terms of landscape character, navigating interests and the experience of those transiting the Sound by boat. The extent of the issues raised regarding pollution and the extent of its suggested consequences for nature conservation prompted the application being held in abeyance for some considerable time, in order to afford the applicant opportunity to address these matters and for them to be assessed in detail by SEPA. Given that pollution issues are largely the remit of SEPA, and having regard to the government position that Planning Authorities should not seek to duplicate other regulatory regimes, it is inappropriate that those matters which are properly the responsibility of SEPA should be revisited as part of this application.
Of those other matters which fall within the remit of the Planning Authority none have been identified which point to the need to withhold planning consent. The proposal is, in part, a relocation of an existing site, and also an enlargement of production capacity. It enables the removal of first generation equipment and the use of more modern techniques in a site which is better flushed and which presents opportunity to hold increased biomass without breaching SEPA’s environmental quality standards. It would maintain a single presence of aquaculture development at the southern end of the Sound and would enable an increase in production capacity without seriously prejudicing any of the considerations which are material to the determination of the application. In those circumstances it can be considered to be compliant with Local Plan Policy LP AQUA 1 and other relevant development plan policies, and there are no
Page 31 other material considerations identified of such magnitude as to warrant other than planning permission being granted in conformity with development plan policy.
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APPENDIX 11/1066/MFF: NAMES & ADDRESSES OF REPRESENTEES
OBJECTORS:
Miss Samantha Croll 0/1 11 Barrington Drive Glasgow G4 9DS 31/07/2011 O Martin McNally 0/2 6 Roness Drive Glasgow G52 1HB 12/09/2011 O Mr William Todd 0/2 Flat 61 Fergus Drive Glasgow G20 6AH 23/11/2011 O Mr Terence Hollis 1 Cairns Place 1 Cairns Place Dollar FK14 7LH 18/07/2011 O Andrea Jack 1 Cedar Grove Cardross Dumbartonshire G84 5JW 01/08/2011 O Mr Stephen Jowett 1 Church Road Altofts Normanton Wakefield WF6 2NN 18/07/2011 O Dr Douglas Wilcox 1 Colonsay Drive Newton Mearns Glasgow G77 6TY 07/09/2011 O Mr Richard Bath 1 East Hermitage Place Edinburgh EH6 8AA 18/07/2011 O Mr Oliver Jay 1 Felkington Farm Cottages Berwick Upon Tweed TD15 2NR 07/09/2011 O Mr Stephen Milner 1 High Street Eydon Northamptonshire NN11 3PP 20/07/2011 O Mr Richard Wesley 1 Kilbrandon Cottages Balvicar Oban PA34 4RA 20/07/2011 O C Jade 1 Mahonia Drive Langdon Halls Basildon Essex SS16 6SD 05/08/2011 O Mrs Susan Clarke 1 Mc Calls Terrace Oban PA34 4JE 21/07/2011 O Rosanna Salter 1 Rock Farm Cottage Nettlestead Maidstone Kent ME18 5HT 22/08/2011 O Hugo Salter 1 Rock Farm Cottages Gibbs Hill Nettlestead Maidstone Kent ME18 5HT 22/08/2011 O Monica Patnain 1 Sophia Square London 03/08/2011 O
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SE16 5XL Mr Keith Morris 1 West View Church Road Grange over Sands LA11 7RB 26/07/2011 O Mrs Deborah Chopping 10 Burywick Harpenden AL52AE 25/07/2011 O Mrs Rita Summers 10 Napier Road Monton Eccles Salford M30 8AG 22/07/2011 O Kay Griffin 10 Roseworth Crescent Newcastle NE3 1NR 12/09/2011 O Nathan And Nicola Brown 10 St Marys Close Roughton Norfolk NR11 8QF 03/08/2011 O David Maseska 1000 Chestnut Drive Longmount Colorado USA 80503 03/08/2011 O Kristen Maseska 1000 Chestnut Drive Longmount Colorado USA 80503 03/08/2011 O Judy Murphy 101 Flatford Place Kidlington Oxford OX5 1TG 30/09/2011 O Dr Anthony Beck 102 Potovens Lane Wakefield WF1 2LQ 06/09/2011 O Mr Juan Rodriguez Dominguez 105 Dewi Clos Saint Cardiff CF11 9EX 19/07/2011 O Dr Stella Pytharouli 107 Rottenrow Glasgow G40NG 19/07/2011 O Carole Thomas 108 Eaton Road Appleton Abingdon Oxon OX13 5JJ 30/09/2011 O Alex Dimopoulos 109 Cleveland Road North Sheilds Tyne And Weir 19/08/2011 O B A Laroult 109 Cleveland Road North Sheilds Tyne And Weir 16/08/2011 O J A Lamont 109 Cleveland Road North Sheilds Tyne And Weir NW29 0PF 16/08/2011 O Morven Hughes 109 Cranbrook Road Bristol BS6 7DA 01/09/2011 O Mrs Dorothy Kisielewski 10Allanbank Road Kinbuck Dunblane FK15 0NH 18/07/2011 O Mr And Mrs P Hires 11 Balvicar Isle Of Seil Oban ARGYLL 01/08/2011 O
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PA34 4TF Dr Tony Bennett 11 Cairnbaan Cottages Cairnbaan Lochgilphead PA31 8SJ 28/07/2011 O Ms Jill Watkins 11 Church Lane Walthamstow Village London E17 9RN 20/07/2011 O Mr Angus Morrison 11 Coolin Drive Portree IV51 9DN 21/07/2011 O Jean L Alexander 11 Cullipool Village Isle Of Luing By Oban PA34 4UB 04/08/2011 O Miss Kathleen Cowie 11 Donmouth Road Aberdeen AB23 8DT 02/08/2011 O Mrs Vivienne Merrick 11 Eldridge Close Pendeford Wolverhampton WV9 5PX 18/07/2011 O Tim Wray 11 Hoole Road Broomhill Sheffield S10 5BH 03/08/2011 O Mrs Alison Wray 11 Hoole Road Sheffield S10 5BH 01/08/2011 O Mr Cliff Pearn 11 Oak Apple Close Saltash Cornwall 19/07/2011 O Miss Rachel Godden 11 Scotland Hill Sandhurst GU47 8JR 14/07/2011 O Robert Godden 11 Scotland Hill Sandhurst Berks GU47 8JR 16/08/2011 O S Goridge And S Eldnoye 11 St Aethans Drive Burfhead Moray IV30 5GP 03/08/2011 O Dr Kate Dunn 11 Woolliscroft Ave Newcastle ST5 0NR 02/08/2011 O Mr John Whitley 111 Divinity Road Oxford OX4 1LW 18/07/2011 O Mr Robin Gallamore 112 Derby Road Melbourne Derby DE73 8FL 03/08/2011 O J Currie 115 Town Way West Towyn LL22 9LF 12/09/2011 O Mr Fraser Robertson 1173 Gallowgate Glasgow G31 4EG 03/08/2011 O Sheila Brook 11A Hazelmore Avenue Newcastle Upon Tyne NE3 5QL 05/08/2011 O David Brook 11A Hazelnut Avenue Newcastle Upon Tyne NE3 5QL 22/08/2011 O Mr Adrian Lough 12 Dundrenann Cottages Edinburgh EH16 5RG 06/09/2011 O
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Dr Fiona Lough 12 Dundrennan Cottages Edinburgh EH16 5RG 03/10/2011 O Mrs Helen Butland 12 Forde Close Newton Abbot TQ12 5NN 17/07/2011 O L Bradshaw 12 Maida Grove Fulford Road York YO10 4EU 16/08/2011 O Mr Robert Ferguson 12 Polmont Road Laurieston Falkirk FK2 9QY 07/08/2011 O Jean Rhoades 12 The Greens Glencruitten Road Oban Argyll PA34 4DD 16/09/2011 O Andrea Sturniolo 125 Clarence Road London E5 8EE 01/09/2011 O Miss Pamela Mcleish 1-29 Esplanade Court Corran Esplanade Oban PA34 5PW 21/07/2011 O Miss Nicola Simmons 13 Broadwater Gardens Orpington BR6 7UQ 18/07/2011 O Mrs Jackie Simmons 13 Broadwater Gardens Orpington BR6 7UQ 18/07/2011 O Mrs Dawn Crowe 13 Roselea Drive Glasgow G62 8HE 26/07/2011 O Mr David Rillie 13 Wanless Court Musselburgh EH21 7QU 19/07/2011 O Mr Tom Gallagher 13, Moor Rd Cartland Lanark ML117RE 24/07/2011 O Mrs Alison Tamea 133 Seaton Road Hemel Hempstead HP3 9HU 19/07/2011 O Mr Hug Kerr 14 Brierie Aveonue Crosslee Johnstone PA6 7BQ 12/09/2011 O Ms Christine Page 14 Brucehaven Road Limekilns Dunfermline KY11 3HZ 08/09/2011 O S Teefer 14 Cnoc A Challtuinn Clachan Seil By Oban Argyll PA34 4TR 03/08/2011 O Diane McVeigh 14 Tor Close Waterlooville Hampshire PO7 8SU 12/09/2011 O Mr Paul Stanier 14, Collinbourne Close Trentham Stoke-on-Trent ST4 8GU 03/08/2011 O Ms. Franka Leehr 14/8 Roseneath Place Edinburgh EH9 1JB 18/07/2011 O
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Mr Stephen Miller 143 Craig Street Darlington DL3 6H 17/07/2011 O Name Illegible 144 Bewdley Hill DY11 6BT 26/08/2011 O Neil Weddell 147 Riverstone Way Northampton NN4 9QW 16/08/2011 O Dr Inglis Lamont 148 Sinclair Street Helensburgh G84 9AT 21/07/2011 O Susan Wharton 15 Balvicar Seil Island Oban Argyll PA34 4TF 03/08/2011 O Miss Pamela Ocampo 15 Bruce Road Glasgow G41 5EN 18/07/2011 O Sheila Urquhart 15 Geils Avenue Dumbarton G82 2QJ 25/07/2011 O Mrs Kim Morgan 15 Hutton Avenue Hartlepool TS26 9PW 17/07/2011 O A Dechmilemot 15 Parker Streeet Dundee UK DD1 5RZ 03/08/2011 O Miss Rosanna Forbes 15 Randolph Crescent Edinburgh EH2 7TT 18/07/2011 O Jenny Underwood 15 Thornhill Terrace Sunderland SR2 7JL 20/10/2011 O Mrs Maggie Bowie 15 Victoria Street Alloa FK10 2DZ 19/07/2011 O MR Mark Patton 15 Waincliffe Crescent 15 Waincliffe Crescent Leeds LS11 8EU 18/07/2011 O Miss Seonaid Reid 15/1 Orchard Brae Gardens Edinburgh EH4 2HQ 26/07/2011 O Mr David Robinson 154 Belper Lane Belper Derbyshire DE56 2UJ 23/07/2011 O Ian Whyte 16 Combie Court Glencruitten Road Oban Argyll And Bute PA34 4BY 26/07/2011 O Mr Trevor Taylor 16 Fairway Gardens Pendine Park Gwersyllt LL11 4XB 18/07/2011 O J Walford 16 Fife Road Darlington DL3 7SY 05/08/2011 O Pauline McCluskey 16 Rivermead Road Exeter EX2 4RL 05/08/2011 O Mr Jock Souter 16 Tinto Drive Cumbernauld G68 9BF 19/07/2011 O Mt Tony Walsh 16, Eagle Terrace Woodford Green IG8 9AT 16/08/2011 O
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Miss Kirsty Dunn 16/3 Chancelot Terrace Edinburgh EH6 4SS 18/07/2011 O Mr Timothy Elliott 16/3 Chancelot Terrace Edinburgh EH6 4SS 18/07/2011 O Miss Kristine Bird 17 Bouverie Street Flat 3/3 Glasgow G14 0PD 20/07/2011 O Ian Poyner 17 Fir Grove Whitehill Bordon Hants GU35 9ED 12/09/2011 O Professor Jeremy Cresswell 17 Kestrel Road Newburgh Ellon AB41 6FF 07/01/2012 O Miss Caroline Warburton 17 Landel Street Markinch KY7 6AG 25/07/2011 O Mr Martyn Tunstall 17 North Gyle Park Edinburgh EH12 8LE 05/09/2011 O Jill And Brian Hallett 17 Strone Close Botley Oxford EX2 9SQ 30/09/2011 O Ms Deanna Austin-Crowe 17 Townend Cresc Stoke Goldington Bucks MK168NU 03/08/2011 O Mr James Doonan 170 Beeches Road Clydebank G81 6JH 24/07/2011 O Mary Doonan 170 Beeches Road Clydebank G81 6JH 03/08/2011 O Mr Stephen Hines 174B Iverson Road London NW6 2HL 17/07/2011 O Mr Matthew Mercer 175 West Point Wellington Street Leeds LS1 4JL 18/07/2011 O Viktor Bale 18 Harvester Close Greenleys Milton Keynes MK12 6LE 12/09/2011 O Ms Pamela Harrison 18 Leslie Road Dorking RH4 1PS 18/07/2011 O J Carr 18 Main Street Lambley Nottingham NG4 4PN 22/08/2011 O Mr Gary Henshaw 18 Queens Avenue Ilkeston DE7 4DL 18/07/2011 O L G Speers 18 Scaribrick Close Maghull Merseyside L31 9PG 02/09/2011 O J Speers 18 Scarisbrick Close Maghull Merseyside L31 9PE 01/09/2011 O
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Sandra Speers 18 Scarisbrick Close Maghull Merseyside L31 9PE 01/09/2011 O Brain Heaton 18 Toberonochy Village Oban Argyll PA34 4UE 01/08/2011 O Mr Charlie Fayers 18 Villiers Lane Oxford OX4 4HY 16/07/2011 O Mr. David Llewelyn 183 Churchill Drive Glasgow G11 7EY 09/08/2011 O Mrs Ruth Llewelyn 183 Churchill Drive Glasgow G11 7EY 09/08/2011 O Graham Sparshott 19 Inverewe Place Dunfermline Fife KY11 8FH 16/08/2011 O Carina Sparshott 19 Inverewe Place Dunfermline Fife KY11 8FH 16/08/2011 O Miss Christine Birch 19 Queensway Sunbury On Thames TW16 6HA 20/07/2011 O Pat Leach 19 Toberonochy Oban Argyll PA34 4UE 03/08/2011 O Mr John Planck 19 Wheal Regent Park, Carlyon Bay St Austell PL25 3SP 19/07/2011 O L MacDonald 192 Cedar Drive Perth PH1 1RJ 26/08/2011 O Neil MacDonald 192 Cedar Drive Perth PH1 1RJ 26/08/2011 O Jan Veale 1A Girdlestone Road Headington Oxford OX3 7LZ 30/09/2011 O Alex Gibson 1A Girdlestone Road Oxford OX3 7LZ 30/09/2011 O Nigel Scriven 2 Alt Na Blathaich Loch Eck Dunoon Argyll PA23 8SG 25/07/2011 O Miss Wendy Underwood 2 Brandon Road Wordwell Bury St. Edmunds IP286UL 03/08/2011 O Miss Joanne Millett 2 Bryn Road South Ashton In Makerfield Wigan WN4 8QR 18/07/2011 O Mrs Alison Laurie 2 Corum Place Blackford Auchterarder 12/10/2011 O Miss Diane Elliott 2 Cruachan Buildings Lochawe Dalmally PA33 1AJ 19/07/2011 O
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Ms Fiona Maguire 2 Cuddy Lane Edinburgh EH10 4TQ 09/09/2011 O Mrs Mary Williams 2 Dewberry Close Stourport on Severn DY13 8TB 19/07/2011 O Ms Myra Kinghorn 2 Ely Close Crawley RH10 5JL 18/07/2011 O Elaine Plenderleith And Hugh 2 Fyne Road Plenderleith Broughty Ferry Dundee DD5 3JF 16/08/2011 O Greg Walton 2 Great Calcroft Pershore Worcestershire 03/08/2011 O Joshua J Walton 2 Great Calcroft Pershore Worcestershire WR10 1QS 03/08/2011 O Sam Walton 2 Great Calcroft Pershore Worcs WR10 1QS 03/08/2011 O Mrs Myra Waddell 2 Kilbrandon Cottages Balvicar Seil PA34 4RA 03/08/2011 O Mr Martin Waddell 2 Kilbrandon Cottages Balvicar, Isle of Seil PA34 4RA 03/08/2011 O Mr Neal Setterington 2 Kirklands Villas Baildon D176HJ 03/02/2013 O Miss Mary Watson 2 Magdala Mews Edinburgh EH12 5BX 25/07/2011 O Mr Charlie Hussey 2 Magdala Mews Edinburgh EH12 5BX 25/07/2011 O Ms Belinda Magee 2 Mount Hey Somerton TA11 7PG 19/07/2011 O Mrs Elizabeth Minton 2 New Hall Bouth Ulverston LA128JJ 18/07/2011 O Mrs Sarah Bealey 2 St Georges Cottages South End, Damerham Fordingbridge SP6 3HP 18/07/2011 O Miss Shirley Robson 2 St Pancras Close Dinnington Sheffield S25 3RX 10/09/2011 O Mr Christopher Ashley 2 Yew Tree Villas Hare Lane chester CH3 7EG 29/07/2011 O Mrs Caragh Ashley 2 Yew Tree Villas Hare Lane, Pipers Ash Chester CH3 7EG 29/07/2011 O Ms Helen Jones 2, Kirkhill Court Broxburn EH52 6HS 03/10/2011 O V Robinson 2/1 4 Craiglea Drive Edinburgh EH10 5PA 16/08/2011 O
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Mr Ben Byrne 2/1 46 Bentinck Street Glasgow G3 7TT 18/07/2011 O Mrs Gail Mackay 2/3 North Leith Mill Edinburgh EH6 6JY 24/07/2011 O Mr Andrew McWilliams 20 Church Street Ainsworth Bolton BL2 5RT 18/07/2011 O mrs Susan Johnston 20 Creag Bhan Village Oban pa34 4bf 23/07/2011 O Mrs Elaine Telfer 20 Davies Drive Alexandria G83 0UH 20/07/2011 O Ms Ronnie Mcleod 20 Ferryfield Gardens Alexandria Dunbartonshire G83 0TB 28/07/2011 O Mr And Mrs Kitson 20 Hunters Grove Hunters Quay Dunoon Argyll PA23 8LQ 12/09/2011 O Mr Michael Whitley 2001 Route De Corps Saint Martin D'Uriage 38410 19/07/2011 O Mrs. Sheila Costigan 201 Crook Ave. La Grande OR, USA 97850 20/07/2011 O Dr Bandana Malhotra 205 Clarence Lane London SW15 5PZ 01/08/2011 O Miss Sudeshna Choudhury 205 Clarence Lane London SW15 5PZ 26/07/2011 O Mrs Dplali Choudhury 205 Clarence Lane London SW15 5PZ 27/07/2011 O Mr Jamie Inglis 21 Aird's Crescent Argyll Square Oban PA34 5SJ 31/08/2011 O Mrs Emma Inglis 21 Aird's Crescent Argyll Square Oban PA34 5SJ 31/08/2011 O Master Hamish Inglis 21 Airds Crescent Oban PA355SJ 31/08/2011 O Jeremy Inglis 21 Airds Crescent Oban Argyll PA34 12/08/2011 O Ms Katrin Josepeit 21 Aird's Crescent Oban PA34 5SJ 11/08/2011 O Mr Robbie Wightman 21 Clifford Road North Berwick EH39 4PW 26/07/2011 O Mrs. Deborah Mcdonald 21 Lindisfarne Road, Newcastle upon Tyne Newcastle upon Tyne NE2 2HE 03/08/2011 O B A Fothyill 21 Weald Close Brentwood Essex CM14 4QV 05/08/2011 O
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Paul Beckett 21 Weald Close Brentwood Essex CM14 4QV 05/08/2011 O Phillip Gate 21/5 Steads Place Edinburgh EH6 5DY 12/09/2011 O Alan Hinchliffe 210 Rainhill Road Rainhill Merseyside L35 4LD 16/08/2011 O Laura Hinchliffe 210 Rainhill Road Rainhill Merseyside L35 4LD 16/08/2011 O Mr Bill Gray 22 Branziert Road North Killearn G63 9RF 07/09/2011 O Ms Dawn Kelly 22 Cell Barnes Lane St. Albans AL1 5RA 27/07/2011 O Dr Alan McLelland 22 Corlic Way Kilmacolm PA13 4JD 18/07/2011 O Birgit Whitmore 22 Cullipool Luing PA34 4UB 03/08/2011 O Mr Alastair Currie 22 Edinburgh Road Biggar ML12 6AX 28/01/2013 O Mr Justin Williams 22 Embleton Road Lewisham London SE13 7DH 18/07/2011 O Miss Patricia Hughes 22 Hazel Road Bradmore Wolverhampton WV3 7HB 18/07/2011 O Mrs Julie Keetley 22 Iona Drive Trowell Nottingham NG9 3RF 19/07/2011 O Name Illegible 22 Neville Crescent Acton Wrexham LL12 7HE 25/08/2011 O Alex Wellbelove 220 Tonbridge Road Wateringbury Maidstone Kent ME18 5NX 22/08/2011 O Mr Jim Anderson 224 High Street Linlithgow EH49 7ES 18/07/2011 O Mr David Burns 23 Clive Rd, Highcliffe 23 Clive Rd Christchurch BH23 4NX 18/07/2011 O Ms Wendy Axford 23 Clive Road Highcliffe Christchurch BH23 4NX 18/07/2011 O R Farrell 23 Foulsykes Road Cambusnethan Wishaw 03/08/2011 O Mrs Joanne Davenport 23 Kingsmuir Avenue Preston PR2 6AG 21/07/2011 O
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Mrs Victoria Colville 24 Mill Cottage Park Newtownards BT22 2FF 18/07/2011 O E Vincent 24 Preston Avenue ME30 2BS 16/08/2011 O Catherine Vincent 24 Preston Avenue North Sheilds Tyne And Weir NE30 2BS 16/08/2011 O Emma Nicole Vincent 24 Preston Avenue North Sheilds Tyne And Weir NE30 2BS 16/08/2011 O Lucy Gladden 24 The Larches Faversham Kent ME13 7SQ 05/08/2011 O Robert Gladden 24 The Larches Faversham Kent ME13 7SQ 05/08/2011 O Miss Emma Williams 24/6 Milton Street Edinburgh EH8 8HE 18/07/2011 O Miss Lucy Smith 240 Coteford Street London SW17 8NL 18/07/2011 O Mr David Simpson 25 Majors Loan Falkirk FK1 5QG 24/07/2011 O Ian McIntyre 25 Stravaig Walk Paisley PA2 0RX 11/10/2011 O Anna Dalliniort And Ben Dalliniort 25 Toberonochy Isle Of Luing Oban Argyll PA34 4UE 05/08/2011 O Rev. Mr. Derek Corner 254 Lime Crescent Abronhill Cumbernauld G67 3PH 17/07/2011 O Ms Judith Wilson 26 Clarence Street Edinburgh EH3 5AF 02/08/2011 O Ms Jeanette Tsang 27 Guildford Grove London SE10 8JY 19/07/2011 O Dr Rosalind Glasspool 27 Banavie Road Glasgow G11 5AW 23/07/2011 O Miss Isabel Miguelez 27 Baxter Park Terrace Dundee dd4 6nr 27/07/2011 O Mr James Watson 28 Sandwell Crescent Kirkcaldy KY1 1GH 05/09/2011 O Sam Johnson 29 Barclay Park Aboyne Aberdeenshire AB34 5JF 05/08/2011 O Mr Francis Connelly 29 Colquhoun Road Milton Dumbarton Glasgow G82 2TH 03/08/2011 O Mrs Caroline Gwilliam 29 Hilltop Road Whyteleafe CR3 0DF 03/08/2011 O
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Mrs H Cameron 3 Ardloch Cottages Glenburn Road Ardrishaig Argyll PA30 8EU 12/09/2011 O Jeremy Iles 3 Barrhill Close Great Barr Birmingham B43 6LS 03/08/2011 O Ms Katryn Mercer 3 Brookside Sutton Ely Cambs 18/07/2011 O Miss Laura Gamble 3 Chesnut Avenue Radley College Abingdon OX14 2HS 18/07/2011 O Mrs Margaret MacLachlan 3 Claymhor, Hillview Drive Corpach Fort William PH33 7LS 21/07/2011 O Mr Willie Fulton 3 Drinishader Isle Of Harris HS3 3DX 18/10/2011 O Mr Richard Goodson 3 High Grizebeck Grizebeck Kirkby-in-Furness LA17 7XJ 18/07/2011 O Mr Ben Mitchell 3 Kilmun Court Dunoon pa23 8sf 20/07/2011 O Ms Lindsay Gilmour 3 Lyppiatt Road Bristol BS5 9HW 01/08/2011 O Mrs Anne-Marie Geoffrion-Pfeil 3 Rue De Walbourg Schiltigheim F 67300 18/07/2011 O Holly Abrol 3 Ryefield Close Solihull West Midlands B91 1PP 16/08/2011 O James Robertson 3 St Michaels Knowe Garelochhead Helensburgh G84 ODQ 25/07/2011 O Mr Peter Mackie 3 Stanley Avenue Wallasey CH45 8JN 03/08/2011 O Mr Andrew Newton 3 The Avenue, Southlands Haxby York YO322PD 18/07/2011 O Mr Michael Long 3 Walkers Mount Meanwood Leeds LS6 2SD 20/07/2011 O Donald Manson 3 West Street Dunoon Argyll PA23 8EB 08/08/2011 O Miss Eala Williams 3 Whin Bank Clachan Siel Oban 03/08/2011 O Miss Elodie Megaoui 3/1 Coinyie House Close Edinburgh EH1 1NL 18/07/2011 O Mr Julien Valentin 3/1 Coinyie House Close Edinburgh EH1 1NL 18/07/2011 O
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Mr Tom Learoyd 3/2, 3 Dowanside Road Glasggow G12 9YB 01/08/2011 O Miss Amy Ferguson 3/6 Warrender Park Terrace Edinburgh EH91JA 24/07/2011 O Miss N Tobin 30 Cornwall Road Manchester M437PR 18/07/2011 O Mr Peter Dutton 30 Toberonochy Island of Luing By Oban PA34 4UE 22/07/2011 O Guy Lidbury 31 North St Maldon Essex England CM9 5HH 05/08/2011 O Ms Anita Machin 310 Design House Manchester M4 1BH 18/07/2011 O Mrs Carolyn Evans 310 Yewdale Skelmersdale WN86ES 26/10/2011 O Mr Alan Hawkins 32 Barr Mor View Kilmartin PA31 8UN 20/07/2011 O Mrs C Cardy 326 Millfield Hill Erskine PA8 6JN 17/07/2011 O Mr MIke Redhead 34 Derrymore Road Willerby HU10 6ES 04/08/2011 O Miss Heather Hutchings 34 Drakeley Court Aubert Park London N5 1TT 03/08/2011 O David Milburn 34 Newquay Close Nuneaton Warwickshire CV11 6FH 03/08/2011 O Mr Boyd Tunnock CBE 34 Old Mill Road Uddingston Glasgow G71 7HH 02/09/2011 O Gerry Taylor 3446 Plymouth Road Victoria B.C. Canada 12/09/2011 O Ms Elke Braun 35 Weavers Way Tillicoultry FK13 6BD 02/08/2011 O Mr Paul Branney 36 Millar Street Carnoustie DD7 7AT 28/07/2011 O Mrs Wendy Kirby 36 Rowallan Road London SW6 6AG 22/07/2011 O Mrs Lois Skilleter 36, Skipton Road Ilkley LS29 9EP 10/09/2011 O Mr Larry Rumbol 37 Daniells Walk Lymington SO41 3PP 18/08/2011 O Mrs Nele Andersch 37 Daniells Walk Lymington SO41 3PP 18/08/2011 O
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Ms Colette Coleman 37 Hawthorne Gardens Hockley, Essex SS5 4SW 18/07/2011 O Mr Alan Smith 37 High St. Dunbar EH42 1EW 14/09/2011 O Miss Doune Fairfax 37/4 William Street Edinburgh EH3 7LW 19/07/2011 O Miss Jo Fowler 38 Kinneil Drive Bo'ness EH510LY 17/07/2011 O Belcho Petrov 38 Norbroke Street London W12 0QX 10/08/2011 O Mr Stephen Mawdsley 388 Newchurch Road Rawtenstall Rossendale BB47SN 18/07/2011 O Mr Roy Morrison 39 Blackhill Drive Helensburgh G84 9AF 24/07/2011 O Mrs June Morrison 39 Blackhill Drive Helensburgh G84 9AF 22/07/2011 O T Cunliffe 39 St John Street Newton Le Willow Merseyside WA12 9NW 16/08/2011 O L Cunliffe 39 St John Street Newton Le Willows Merseyside WA12 9NW 16/08/2011 O Dr Denise Cowley 39 Toberonochy Toberonochy Village Luing Oban PA34 4UE 17/07/2011 O Mrs Bryony Wells 3a Fairfax Road Leeds LS11 8SY 20/07/2011 O Miss Hannah James 3A Stone Villas Leeds LS6 4AA 18/07/2011 O Dr Emeka Mosanya 3c Welbeck Mansions London NW6 1QX 19/07/2011 O Ms Melanie Berard 3F2 34 Spottiswoode rd Edinburgh EH91BL 19/07/2011 O Mr Eamonn Corking 4 Belgrave Road Billericay CM12 0TX 09/08/2011 O Clare E Metcalfe 4 Coppy Bridge Drive Rochdale Greater Manchester England 26/08/2011 O Daniel Robinson 4 Cranley Drive Edinburgh EH10 5PA 16/08/2011 O Ian Callaghan 4 Delamore Way Oxford OX2 9HZ 11/10/2011 O Mr James Macleod 4 Lonan Drive Oban Oban Argyll And Bute PA34 4NN 19/07/2011 O Mr Paul Douch 4 Marsh Lane, Somerleyton Lowestoft NR32 5QX 27/07/2011 O
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B Currie 4 St Georges Crescent RHYL Wales 12/09/2011 O Prof Roger Waigh 4 The Meadows Helensburgh G84 9EG 19/07/2011 O Mrs Tina Avery 4 Toberonochy Isle of Luing PA34 4UE 25/07/2011 O Dr Brice Avery 4 Toberonochy Isle of Luing EH9 1LW 21/07/2011 O Ms Jennifer Willis 4/31 Forrest Rd Edinburgh EH1 2QP 19/07/2011 O Bret Hopping 40 Fir Copse Road Parbrook PO7 5HZ 12/09/2011 O Mrs G Ringrose 40 Gadebridge Lane Hemel Hempstead HP1 3HF 25/07/2011 O Mrs Isabel Carter 41 Leeds Old Road Heckmondwike WF16 9AA 25/07/2011 O Mr Philip Carter 41 Leeds Old Road Heckmondwike WF16 9AA 25/07/2011 O Mr Neil Kennedy 41 Marlborough Avenue Glasgow G11 7BP 13/08/2011 O Mrs H R Graham 41 Toberonochy Village Toberonochy Isle Of Luing PA34 4UE 03/08/2011 O Ms. Sara Reader 410 N Monroe Gardner 60424 18/07/2011 O Mr. Sean Nore 412 34th St West Des Moines 50265 08/09/2011 O Mr Hugh Gray 42 Cullipool Isle of Luing Oban PA34 4UB 04/08/2011 O Ms Alessia Kockel 42 Mersham Drive London NW9 9PN 18/07/2011 O Mr Roderick Millar 42 Moray Place Edinburgh EH3 6BT 19/07/2011 O Mr Stuart McLoughlin 43 Church Road Trull Taunton TA3 7LG 21/07/2011 O Ms Melanie McLoughlin 43 Church Road Trull TA3 7LG 20/07/2011 O U Richardson 43 Fairstead Birch Green Skelmersdale Lancashire WN8 6RB 16/08/2011 O W Richardson 43 Fairstead Birch Green Skelmersdale WN8 6RB 16/08/2011 O Miss Edna Ewan 44 Eastside Drive Westhill AB32 6QN 17/07/2011 O
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Mr John Lowe 44 Woodside Drive Forres IV36 2UF 25/07/2011 O Mrs Ann Turner 45 Hillhead Coylton Ayrshire KA6 6JT 13/09/2011 O Ms. Sara Macdonald 46 Bentinck St. Glasgow G37TT 18/07/2011 O Mrs Sheila Johnson 46 Cleveland Place Peterlee SR8 2PA 18/07/2011 O Mr Joe McIntyre 46 MacLeod Drive Helensburgh G84 9QU 25/07/2011 O Mrs Cathy McIntyre 46 MacLeod Drive Helensburgh G84 9QU 25/07/2011 O Ms Geraldine Joaquim 46 Sturt Road Haslemere GU27 3SD 18/07/2011 O Mr Stephen Tame 46 West Street Devon TQ13 7DU 18/07/2011 O Miss Meilisa Blackham 47 Hampton Hill Wellington Telford TF1 2ER 17/07/2011 O Mrs Sheila Blackham 47 Hampton Hill Wellington Telford TF1 2ER 17/07/2011 O C J Holby 47 Manor Road South Woodham Ferrers Essex CM3 5PT 16/08/2011 O K Holby 47 Manor Road South Woodham Ferrers Essex CM3 5PT 16/08/2011 O Mr Peter Tickle 47, Brown Lees Road Biddulph Stoke-on -trent ST8 6PJ 03/08/2011 O Miss Nicola McMurtrie 48 Edmund Kean East Kilbride G74 3RG 29/07/2011 O Mr David Dougal 49 Balfour Street Edinburgh EH6 5DP 16/09/2011 O Mr & Mrs John and Fiona Watson 49 Broompark Drive Newton Mearns Glasgow G77 5DZ 22/08/2011 O Mr Greg Rust 49 Hayes Hill Bromley BR2 7HN 22/07/2011 O Mr Colin Thirlwall 49 London Road Godmanchester PE29 2HZ 23/08/2011 O D Mitchell 493 Lodge Lane Solihull West Midlands B92 8NT 16/08/2011 O J Mitchell 493 Lodge Lane Solihull West Midlands B92 8NT 16/08/2011 O
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Mr James Heward 5 Benvoullin Gardens Oban PA34 5DL 19/07/2011 O Mr Graham Muir 5 Calside Avenue Paisley PA2 6DD 22/07/2011 O Margarithe Haffner 5 Church Path Chiswick W4 5BL 26/08/2011 O Mr Roddy Campbell 5 Drinishader Harris HS33DX 19/10/2011 O Dr Mark Steer 5 Elberton Road Olveston BRISTOL BS35 4DD 18/07/2011 O S E Oaly 5 Matthews Yard Reepham Norfolk NR10 4NF 16/09/2011 O Mr Kim Ley 5 Mount Close Bristol BS36 2DD 18/07/2011 O Mr Frank Ford 5 Pennine View Glasson Dock Lancaster LA2 0AS 26/07/2011 O Miss Victoria Ashton 5 Randle Drive Sutton Coldfield b75 5lh 02/08/2011 O Mrs Susan Eldred 5 Stanhope St Hereford HR4 0HA 03/08/2011 O Mr Chris Eldred 5 Stanhope St Hereford HR4 0HA 03/08/2011 O Martha, Molly And S Eldred 5 Stanhope Street Hereford HR4 0HA 03/08/2011 O Mr Thomas Wilson 5 Stellhead Avenue New Cumnock KA18 4JT 20/07/2011 O Reverand Frank Front 5 Toberonochy Oban PA34 4UE 26/07/2011 O Ms Janine Ogilvie 5 Tynemouth way Heaton Newcastle NE6 2RZ 19/07/2011 O Miss Harriet Carp 5 Webbs Road London SW11 1XJ 22/07/2011 O Mr Henry Procter 5, The Sycamores, Glossop SK13 2BS 18/07/2011 O Claire Matson 50 Bellahouston Drive Glasgow G52 1HQ 12/09/2011 O Dr Jeremy Bass 51 Tinto Road Newlands GLASGOW G43 2AH 26/07/2011 O Mr Paul Leitch 51 Woodhall Bank Edinburgh EH13 0HL 14/09/2011 O A McNally 52 Fen End Lane Spalding Lincs PE12 6AD 12/09/2011 O
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R McNally 52 Fen End Lane Spalding Lincs PE12 6AD 12/09/2011 O Miss Cherie Bettison 52 Glen Gardens Callander, FK17 8ES 19/07/2011 O Mr Stephen Outhwaite 52 Woodlands Drive Harrogate HG2 7AX 16/08/2011 O Mr John Hanmer 52, Broomleaf Road, Farnham, GU9 8DQ 17/05/2012 O Name Illegible 53 Churchfields Milltown Dublin 14 Republic Of Ireland 26/08/2011 O Mr Richard Gonzalez 535 Portswood Road Southampton so173sa 02/08/2011 O Mr Daniel Sidoli 54 Halstead Road Winchmore Hill London N21 3DS 19/07/2011 O Mr Ben Burns 54 Thames Close Hampton TW12 2ET 19/07/2011 O Mr Craig Muirhead 57 Hopefield Road Blackburn EH477HX 18/07/2011 O Mr David Pearson 58 Cambridge Road Crosby Lverpool L23 7TZ 04/08/2011 O Mr Duncan Macdonald 58 Cloan Crescent Bishopbriggs Glasgow G64 2HW 16/08/2011 O Roy And June Stove 6 Acha Balvicar Near Oban PA34 4RJ 03/08/2011 O Mr Charlie Tomlinson 6 Buckingham Street Hillhead Glasgow G12 8DL 25/07/2011 O Mr Simon Gurney 6 Cross Rd Leamington Spa CV32 5PB 19/07/2011 O Mr Barry Carter 6 Elm Court Elmdon Saffron Walden CB11 4NP 18/07/2011 O Andrew Forrester 6 Havelock Road Croydon Surry CR0 6QP 03/08/2011 O Daniel And Celia Hughes 6 High Street Dollar Scotland FK14 7AY 01/09/2011 O Mr David Shenton 6, Ninian's Rise Kirkintilloch Glasgow G66 3HU 03/08/2011 O Miss Weronika Chaberko 6/3 Montague St Edinburgh EH8 9QU 18/07/2011 O
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Sindy Lau 61 Finisterne Parade Port Marine Portishead BS20 7JY 16/09/2011 O Andrew Hill 61 Finisterne Parade Portmarine Portishead Bristol BS20 7JY 16/09/2011 O Michael Walsh 61 Maes Y Wennol Miskin Pontyclun CF72 8SB 10/08/2011 O Belinda Faulkner 61 Princes Street Stone Staffordshire ST15 8HY 05/08/2011 O Ricardo Telmo Fernandes 61 Princes Street Stone Staffordshire ST15 8HY 05/08/2011 O Mr Chris Owen 63 Bath Road Eastington Stonehouse GL10 3AY 07/09/2011 O D Griffin 63 Beswick Gardens Rugby Warwickshire CV22 7PR 10/08/2011 O R B Griffin 63 Beswick Gardens Rugby Warwickshire CV22 7PR 10/08/2011 O Name Illegible 63 Carlton Way Glazebrook Warrington WA3 5BG 16/08/2011 O T Entwistle 63 Carlton Way Glazebrook Warrington WA3 5BG 16/08/2011 O Mr Ian Sharpe 63, Black Butts Lane Walney Island Barrow-in-Furness LA14 3JZ 26/07/2011 O Alison Barnes 67 Simonside Terrace Heaton Newcastle UponTyne NE6 5LF 12/09/2011 O Mrs Marian Hollings 670 Bolton Road BRadford BD3 0ND 10/08/2011 O Mrs Jennifer Petrie 68 Auchmithie Arbroath DD11 5SQ 18/10/2012 O Pamela Hughes 7 Ballaig Avenue Bearsden Glasgow G61 4HA 03/08/2011 O Roger Hughes 7 Ballaig Avenue Bearsden Glasgow G61 4HQ 03/08/2011 O Mrs Peggy Mack 7 Blackhouse Avenue Newton Mearns Blackhouse Avenue G77 5HU 22/07/2011 O Jonathon Ashworth 7 Clarence Grove Leeds LS18 4LA 20/10/2011 O
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Mr Jamie Dyer 7 Cooper Cottages Barrock Thurso KW14 8SZ 17/07/2011 O Mrs Cheryl Power 7 Foxgrove Avenue 7 Foxgrove Avenue Beckenham BR3 5BA 18/07/2011 O Mr Kurt Leech 7 Grangeway Handforth, Wilmslow SK9 3HY 18/07/2011 O Declan And Mairead Currie 7 Grosvenor Avenue Rhyl Wales LL18 4HA 12/09/2011 O Mr Anthony Howard 7 Herontye Drive East Grinstead RH19 4LR 18/07/2011 O K E Mallalratt 7 Myrtle Street Retford Nottinghamshire DN22 7BS 10/08/2011 O Mr John Travers 7 Park Place Thackley BD10 0TG 26/07/2011 O Libby Lawes 7 Queens Road Clevedon BS21 7TH 19/07/2011 O Paul Goddard 7 Roy Avenue Ipswich Suffolk IP3 8LN 03/08/2011 O Mr Alex Campbell 7 Rufford Grove Bingham Nottingham NG13 8RH 03/08/2011 O Mr Michael Walters 7 St James Close Baildon Shipley Bradford BD17 6HF 20/07/2011 O Mr Bill Waugh 7 Thorne Court North Berwick EH39 4RU 26/07/2011 O Amanda Fairclough 7 Time Park Prescot L35 7NU 01/09/2011 O Mrs Julia Galbraith 7 Toberonochy Isle of Luing Oban PA34 4UE 29/07/2011 O Mr Robert Fraser 7 Langhill Farm Cottages Roslin EH25 9ST 18/07/2011 O C Wilson 71 Moore Close Claypole Newark NG23 5AU 26/08/2011 O A E Wilson 71 Moore Close Claypole Newark Notts NG23 5AU 26/08/2011 O J Wilson 71 Moore Close Claypole Newark Notts NG23 5AU 26/08/2011 O
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Mr Gregory Chauvet 73 Hanson Street Glasgow G31 2HF 18/07/2011 O Mr Roger Green 73 Leigh Hall Road Leigh-on-Sea SS9 1QZ 01/09/2011 O Ms Joy Williams 74 Albion Street Wirral Citizens Advice Bureau Wallasey CH45 9JH 18/07/2011 O Leigh Gordon 74 Angle Park Terrace Edinburgh EH11 2JP 03/08/2011 O Mr Colin Iain Macrae 75 Riddochhill Road Blackburn EH477EZ 03/08/2011 O Graham Batty 76 Cardinal Avenue Boreham Wood Herts WP6 1SH 05/08/2011 O Andy McDonald 76 Simonside Terrace Heaton Newcastle Upon Tyne NE6 5LF 12/09/2011 O Mr Carl Wright 77 Oawood Road Bricket Wood AL2 3QB 19/07/2011 O Name Illegible 78 Springwood Avenue Stirling FK8 2PE 26/08/2011 O Miss Shona Forbes 79 Hollinhall Street Greenacres Oldham OL4 3EH 18/07/2011 O Mr Stephen Lee 8 Ash Lane Wells BA5 2LU 20/07/2011 O Agnes M M Connelly 8 Balvicar Isle Of Seil By Oban Argyll PA34 4TF 01/08/2011 O Mrs Carol Ramsey 8 Belmont Close Branton Doncaster DN3 3PU 18/07/2011 O Ms A Otto 8 Harwill Grove Churwell Leeds LS27 7QH 19/07/2011 O J And G Hallan 8 Hill View Whailey Bridge High Peak Derbyshire SK23 7BG 01/08/2011 O Miss Judith Wroe 8 Jennings Avenue Salford M5 3JR 19/07/2011 O Mr Owen Merrick 8 Johnstone Street Alva FK12 5AE 03/09/2011 O Miss Sanccia Thomas 8 Kingfisher Brae Livingston EH54 6UD 02/08/2011 O Mr Peter Wrate 8 Kirkhill Drive Oldmeldrum AB51 0FP 23/07/2011 O Evie Weir 8 Phoenix Court Chertsey Road 16/08/2011 O
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Lower Feltham Middlesex TW13 4RN Lee Weir 8 Phoenix Court Chertsey Road Lower Feltham Middlesex TW13 4RN 16/08/2011 O J Taylor 8 Robin Hood Close St Johns Woking GU21 8SS 26/08/2011 O Mrs Linda Brown 8 Seaview Terrace Easdale Oban PA34 4RG 21/07/2011 O Mrs R D Reading 8 Stafford Street Helensburgh G84 9JU 03/08/2011 O Sylvia Jordan And Colin Jordan 8 Sundown Avenue Littleover Derby DE23 1GY 16/09/2011 O Heather Noble 80 Hutton Avenue Hartlepool TS26 9PR 26/08/2011 O Ian Noble 80 Hutton Avenue Hartlepool TS26 9PR 26/08/2011 O Miss Heather Forbes 80 North Bughtlinside Edinburgh EH12 8YB 17/07/2011 O Mr Shaun Ritchie 81 Haberdasher Street London N16EH 03/08/2011 O Miss Karen Davies 83 Folly Lane Swinton Manchester M27 0DB 17/07/2011 O Naomi Burgoyne 84 Martin Close Deancross Street London E1 2QT 01/09/2011 O Mr Ciaran Hoy 84/6 Hawthornvale Edinburgh EH6 4JX 16/07/2011 O Miss Fern Lear 85, Sunningdale Close Warrington WA5 4NS 18/07/2011 O Mr Daniel Lear 85, Sunningdale Close Warrington WA5 4NS 18/07/2011 O Mr Michelle Lear 85, Sunningdale Close Warrington WA5 4NS 18/07/2011 O Mr Robin Lear 85, Sunningdale Close Warrington WA5 4NS 18/07/2011 O Mr John Mark Mitchell 87/5 Restalrig Road South Edinburgh EH7 6JD 08/09/2011 O Ms Barbara Nock 89 Braehead Cresent Stonehaven ab39 2pp 18/07/2011 O Alison Reynolds 89 Saville Road Whiston Rotherham South Yorkshire S60 4DZ 12/09/2011 O
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John Reynolds 89 Saville Road Whiston Rotherham South Yorkshire S60 4EE 12/09/2011 O Nick Gilmour 9 Balvicar Seil PA34 4TF 01/08/2011 O Dr Tom Hurst 9 Bristol Ave Manchester M19 3NU 25/07/2011 O Mr Adam Cheetham 9 Buttercup Avenue Donisthorpe Swadlincote DE12 7RR 30/07/2011 O Mrs Kate Harris 9 Buttercup Avenue Donisthorpe Swadlincote DE12 7RR 30/07/2011 O Claire MacLeod 9 Citadel Crescent Stromness Orkney KW16 3EL 03/08/2011 O M Mawld 9 Citadel Crescent Stromness Orkney KW16 3EL 03/08/2011 O Ms Susan Yates 9 Clough Lane Grasscroft Odham OL4 4EW 30/07/2011 O William Jones 9 Elleniheich Fasdale Oban Argyll PA34 08/08/2011 O Ms Janet Harbidge 9 Princes Street Stirling FK8 1HQ 29/07/2011 O Mr Osbert Lancaster 9 Sandford Gardens Edinburgh EH15 1LP 22/07/2011 O Mr Martyn Webster 9 Whittingehame Drive GLASGOW G12 0XS 16/08/2011 O Mr Paul DAnaleze 91 Fotheringay Road Glasgow G41 4LH 25/07/2011 O Mr Gordon Laing 93 Falkirk FK2 9DH 20/07/2011 O Mr Frederick Mckenna 93 Hardshaw Street St Helens WA10 1JR 18/07/2011 O Dr Nicola MacLeod 97 Lower Granton Road Edinburgh EH5 1ER 16/07/2011 O Ms Vicky Stirling 9A St Vincent Street Edinburgh EH3 6SW 19/07/2011 O Mrs Pat Blunsden Achabeag Cuan Rd Balvicar PA34 4RJ 18/07/2011 O Neil J McLean Achaleven Farm Connel Oban PA37 1PF 03/08/2011 O Ms G W Stewart Achnaseilach Clachan Seil 01/08/2011 O
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By Oban Argyll PA34 4TJ K W Butler Achraich Clachan Seil By Oban Argyll PA34 4TN 05/08/2011 O Annika Niellweweme Address Illegible 22/08/2011 O C Derriks Address Illegible 22/08/2011 O Christopher Dimonpaulos Address Illegible 16/08/2011 O David Carmichael Address Illegible 10/08/2011 O Ellen De Baare Address Illegible 16/08/2011 O Eva Arents Address Illegible 26/08/2011 O Fam Van Leyenhurst Address Illegible 16/08/2011 O Freeh Van Der Engel Address Illegible 03/08/2011 O Hannah Link Address Illegible 01/09/2011 O Jaap De Baare Address Illegible 16/08/2011 O Jane Maskell Address Illegible 02/09/2011 O Jelmer Krom Address Illegible 22/08/2011 O Jenny Underwood Address Illegible 26/07/2011 O Jirgen Rembold Address Illegible 01/09/2011 O Lorene Korper Address Illegible 22/08/2011 O Maxi Rembold Address Illegible 01/09/2011 O Miguel Fausino Address Illegible 10/08/2011 O Weiner Allee Address Illegible 16/08/2011 O Miss F Morrison Air Tir Balvicar Isle Of Seil PA34 4TF 01/08/2011 O Mrs Ann Wilson Aite Fois Clachan Seil Oban PA34 4QZ 25/07/2011 O Ms Tina Jordan Alltbeath, Musdale Road Kilmore Oban PA34 4XX 20/07/2011 O Name Illegible Alma Cullipool Isle Of Luing Argyll PA34 4TX 05/08/2011 O Thiis Houmans Amberhout 46 1507 EE Zaandam The Netherlands 03/08/2011 O Mr Murdoch Baxter Ampfield Clachan Seil By Oban PA34 4TL 29/07/2011 O Mrs Janice Baxter Ampfield Clachan Seil By Oban PA34 4TL 03/08/2011 O Sheila Downie An Cala Isle Of Seil Argyll PA34 4RF 02/08/2011 O Richard Pierce An Cala South Cuan Isle Of Luing PA34 4TU 18/08/2011 O Ms Carol Collis An Fhuaran Clachan Seil An Fhuaran Oban PA34 4TL 01/08/2011 O
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Mr Mike Williams Annesbrook 2 Dewberry Close Stourport-On-Severn DY13 8TB 18/07/2011 O Mrs Denys Mathieson Appin House, appin, argyll Appin PA38 4BN 04/08/2011 O Dr Peter Thorpe Ar Baile Clachan Seil PA34 4TJ 28/07/2011 O Dr Vivien Johnston Ard Shona Blackmill Bay Luing PA34 4TZ 01/08/2011 O Baba Gana Kasim Ard Shona Blackmill Bay Luing By Oban PA34 4TZ 04/08/2011 O James Lawson Arden-Beag 7 Station Road Craigendoran Helensburgh G84 7BG 25/08/2011 O Christian Taylor Ardencaple House Isle Of Seil Oban Argyll PA34 4TN 04/08/2011 O Name Illegible Ardencaple Isle Of Seil By Oban Argyll PA34 4TN 04/08/2011 O Mrs K Prichard Ardene Harrietfield Perth PH1 3TD 20/07/2011 O Mr Andy Thornton Ardenlinne Ganavan Rd Oban PA34 5TU 24/07/2011 O Mrs Marjie Thornton Ardenlinne Ganavan Road Oban PA34 5TU 24/07/2011 O Mrs Sabina Struthers Ardmaddy Castle Balvicar Oban PA34 4QY 26/07/2011 O Mr A J Struthers Ardmaddy Castle Oban PA34 4QY 26/07/2011 O Charles Struthers Ardmaddy Castle By Oban Argyll PA34 4QY 05/08/2011 O Frances Hill Ardross Clachan Seil Oban PA34 4TL 02/08/2011 O E B Haran Ardtun Clachan Seil Oban Argyll PA34 4TL 03/08/2011 O I E Davies Ardtun Clachan Seil Oban 03/08/2011 O
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Argyll PA34 4TL A Gardiner Ardtun Clachan Seil Oban PA34 4TL 02/08/2011 O Mr Maurice Wilkins Arduaine Garden Arduaine Oban PA34 4XQ 01/08/2011 O Mrs Elizabeth Maclean Aros Ard Croft Road Oban PA34 5JN 20/07/2011 O Mrs Linda Lancaster Ashbeck Brow Edge Road Backbarrow LA12 8QT 18/07/2011 O Miss Elspeth Campbell Asknish Cottage Arduaine by Oban PA34 4XQ 25/07/2011 O Georgina M C McCrae Auchnagoul Cottage Inveraray Argyll PA32 8XT 03/08/2011 O Mr. Kees Rodenburg BadabrieTramore Banavie Fort William PH33 7LX 17/07/2011 O S Brown Ballachan Farmhouse Isle Of Seil By Oban Argyll 01/08/2011 O Mr Ian Provan Balliemore Castleton Lochgilphead PA32 8RU 27/07/2011 O Mr Jamie Mellor Barndromin Farm Knipoch Oban PA34 4QS 22/08/2011 O Antoinette N M Mitchell Barochreal Kilninver By Oban PA34 4UT 28/07/2011 O Antoinette NM Mitchell Barochreal Kilninver Oban Argyll And Bute PA34 4UT 21/02/2013 O Nigel A Mitchell Barochreal Kilninver Oban Argyll And Bute PA34 4UT 21/02/2013 O Jim Bell Basement Flat 15 Hampton Park Bristol BS6 6LG 03/08/2011 O Liz Newton Basement Flat 15 Hampton Park Bristol BS6 6LG 03/08/2011 O Mr Graham Johnston Beck House April Rise Macclesfield SK10 3PJ 23/07/2011 O
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Mr John Landale Berandhu Appin PA38 4DD 08/09/2011 O Mrs. Xandra Van Der Knaap Boomweidelaan 69 Schore 4423AN Netherlands 19/07/2011 O Mrs A P Bevis Braefoot Farm Balvicar Isle Of Seil Oban Argyll And Bute PA34 4RA 26/07/2011 O Mr Michael Handley Bragleenbeg Kilninver Oban Argyll And Bute PA34 4UU 15/08/2011 O Miss Philippa Handley Bragleenbeg Kilninver PA34 4UU 15/08/2011 O Dr Elizabeth Henderson Braidhurst Cottage Kirk Brae Helensburgh G84 8NP 19/07/2011 O Mr John Gould Brown Edge Road Buxton Sk17 18/07/2011 O Mrs J Gould Brown Edge Road Buxton SK17 18/07/2011 O Mrs Helen Smith Brunstane Gardens Penicuik EH26 9AA 10/09/2011 O Linda Broeliema Burg De Bordesstr 74 1404 G2 Bussum The Netherlands 03/08/2011 O Mr Ian Ross Burnbank Ardbroilach Road Kingussie PH21 1JX 26/07/2011 O Ms Alison Prince Burnfoot Whiting Bay Isle of Arran KA27 8QL 18/07/2011 O Mr Andrew Nicol Bute Estate Mount Stuart Rothesay PA20 9LR 27/07/2011 O Mr. Robert Jonsen c/o McNaughton 41 Plann Road, Knockentiber Kilmarnock KA2 0EN 29/07/2011 O Dr Andy Walker C/o Scottish Anglers National Assocaition Ltd The Pier Loch Leven Kinross KY13 8UF 16/08/2011 O Alistair Walker Cairn Ryan Chapel Brae Braemar Aberdeenshire AB35 5YT 05/08/2011 O Catriona Walker Cairn Ryan Chapel Brae Braemar Aberdeenshire AB35 5YT 05/08/2011 O Judge Jeremy Duerden Caladh 17 Lower Cribden Avenue 23/07/2011 O
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Rossendale Lancs. BB4 6SW Dr I Ramsay Calzieveg Braco Perthshire FK15 9RD 26/08/2011 O Sandra Allan Calzieveg Braco Perthshire FK15 9RD 26/08/2011 O Mr Robert Fleck Camusdarach Kilmelford PA34 4XA 03/12/2011 O D S Nicol Carraig Clachan Seil By Oban Argyll PA34 4TL 01/08/2011 O Mr Jon Close Carsaig House Tayvallich Lochgilphead PA31 8PN 21/07/2011 O Mrs Christine Irvine Ceol Mara Glencoe Ballachulish PH49 4HS 21/07/2011 O Mrs M Ann And Mr D Manson Ceol Mara 3 West Street Dunoon Argyll And Bute PA23 8EB 03/10/2011 O Mr John Jordan Chequerfield Close Castleford WF10 5NY 18/07/2011 O Philip Maskell Church Feild Fawley Henley-On-Thames Oxfordshire RG9 6HZ 02/09/2011 O Ms Simone Van Dijl Cluain Cullipool, Isle Of Luing Oban PA34 4UB 03/08/2011 O Brenda McGeoch Cluin Siar Cullipool Isle Of Luing Oban PA34 4TX 03/08/2011 O Wendy And John Mattingley Cluny House Aberfeldy Pethshire PH15 2JT 03/08/2011 O Mr Peter Stott Coille Dharaich Kilmelford PA34 4XD 25/07/2011 O Mr David Stott Coille Dorroch Degnish Road Kimelford PA34 4XD 30/07/2011 O Mrs Helen Glennie Coireseileach Clachan Seil Seil Oban PA34 4QZ 27/07/2011 O Mr David Glennie Coireseileach Clachan Seil Oban PA34 4QZ 20/07/2011 O
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Mrs Linda Battison Cologin Lerags Glen Oban PA34 4Se 20/07/2011 O Mrs Maureen N Jackson Cooraddie Colintraive Argyll PA22 3AT 01/08/2011 O Miss Sue Sayer Copperleaf Cottage Phillack Hill, Phillack Hayle TR27 5AD 17/07/2011 O F E Bisp Coquet Lodge Balvicar By Oban Argyll PA34 4TF 04/08/2011 O J Bisp Coquet Lodge Balvicar By Oban Argyll PA34 4TF 04/08/2011 O Mrs Dorothy Henderson Corrish 84 Bullwood Road Dunoon Argyll PA23 7QL 01/08/2011 O Mr Stephen Whitley Corrymoor Farm Stockland Honiton EX14 9DY 21/07/2011 O Alistair McIntyre Craggan Shore Road Garelochhead Helensburgh G84 0EJ 18/08/2011 O Mrs Ellen-Ann Novak Craig Breck Farm North Kessock By Inverness IV1 3XG 21/07/2011 O Mrs Sandra Boardman Craigroyston Dalmally PA33 1AA 21/07/2011 O Claire Grierson Creag Dubhan Connel By Oban PA37 1PF 03/08/2011 O Isla Grierson Creag Dubhan Connel Oban Argyll PA37 1PF 03/08/2011 O Dr Louise Reid Cruach Scarba Clachan Seil Oban Argyll PA34 4TL 01/08/2011 O Christina M Wills Cuan Ard Cuan Ferry Isle Of Seil Oban Argyll PA34 4RB 03/08/2011 O Dr Kerry Caldock Culzean Rockfield Road Oban PA 34 5 DH 18/07/2011 O Harry T Powell Cumbrae Grosvenor Crescent 04/08/2011 O
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Connel Oban Argyll PA37 1PQ Mrs. Elly Post Curieplaats 65 Rotterdam the Netherlands 3069 HA 02/08/2011 O Mr Post Curieplaats 65 Rotterdam 3069 HA 18/07/2011 O Daniel Smith Dale House The Green Whiston South Yorkshire S60 4JD 12/09/2011 O Marie Smith Dale House The Green Whiston South Yorkshire S60 4JD 12/09/2011 O Mr Andrew Blair-Smith Dalmore House Knipoch By Oban PA34 4QT 26/07/2011 O Mrs Shelley Newton-Carter Dalvey Blairgowrie PH10 7PZ 21/07/2011 O Cath And Eric Strachan Dargo Achaleven Road Connel Argyll 03/08/2011 O R J MacKay Dunara Connel Argyll PA37 1PH 08/08/2011 O Miss Emma Ainsley Dunaverty Easdale by Oban PA34 4RF 31/07/2011 O Mrs Jean Ainsley Dunaverty Easdale By Oban PA34 4RF 31/07/2011 O Mr David Ainsley Dunaverty Easdale Oban PA34 4RF 16/07/2011 O Mr Donald Rice Dundonnell House Dundonnell IV23 2QW 03/08/2011 O Tim Goodwin Dunfillan Cuan Ferry Seil Oban PA34 4RS 25/07/2011 O D And W P Pearson Dunvegan Cnoc A' Challtuinn Clachan Seil Isle Of Seil Oban Argyll And Bute PA34 4TR 26/07/2011 O R Barrett Eaj Mhor Clachan Seil By Oban PA34 4TR 01/08/2011 O Dr J P Moss Ealachan Bhana Clachan Seil Oban 02/08/2011 O
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PA34 4TL K L Barrett And Roger E Barrett Eas Mhor Cnoc - A - Chaltuinn Road Clachan Seil Isle Of Seil By Oban PA34 4TR 01/08/2011 O Mrs Sheila Potts East Coilleard Appin PA38 4BA 23/07/2011 O Mr Orlando Pritchard-Barrett Easter Campsie Farm Glenalmond Ph13RX 20/07/2011 O Mr Michael Heseltine Easter Campsie Farmhouse Glenalmond Perth PH1 3RX 18/07/2011 O Stephen Adam Eastwood Donaldson's Brae Kilcreggan G84 0JB 01/08/2011 O F Macrae EH47 7EZ 03/08/2011 O Dr Rolf Johannessen Elleray, Shore Road Kilcreggan Helensburgh G84 0HG 23/07/2011 O MR Steven Proudfoot Elmer Landscove Newton Abbot TQ13 7LZ 22/07/2011 O R M Chipchase Fascadale Dalriach Road Oban Argyll PA34 5EQ 08/08/2011 O David Fraser Fasgadh Clachan Seil Argyll PA34 4TJ 01/08/2011 O Mrs Diane Scaife Fearnach House Kilmelford Oban PA34 4XD 24/07/2011 O Anne Hughes Fearnoch South Cuan OBAN Argyll PA34 4TU 13/09/2011 O N Robertson Ferniehirst Ganavan Road Oban Argyll And Bute PA34 5TU 26/07/2011 O C J Hughes Ferry House South Cuan Luing Oban Argyll PA34 4TU 16/09/2011 O Mr Richard Downes Fieldgarth Birthwaite Road Windermere LA231BF 18/07/2011 O Mr Glynn Brook Fingland Farm Cottage Wigton CA7 5EN 22/07/2011 O Dr George Hannah Finlaggan Clachan Seil Oban 02/08/2011 O
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PA34 4TL
Mrs Julia Hannah Finlaggan Cachan Seil Oban PA34 4TL 02/08/2011 O Alison Godden Flat 1 Courtyard Mews 105 Boulton Lane Alvaston Derby DE24 0FF 16/09/2011 O Fatima Ferrer Flat 1/2 54 Larchfield Avenue Glasgow G4 9YH 16/08/2011 O Mr Max MacLeod Flat 1-1 23 Polwarth Street Glasgow G12 9UD 06/08/2011 O Mr Nigel Schofield Flat 16 Holyrood Court Prestwich Manchester M25 1PG 24/07/2011 O Marina Johnston Flat 2/1 4 Denby Street Glasgow G3 7TJ 16/08/2011 O Andrew Bush Flat 2/2 764 Pollockshaws Road Glasgow G41 2AE 03/08/2011 O Mr Richard Yeomans Flat 4 9 Shirecliffe Lane Sheffield S3 9AD 22/07/2011 O Jordan Ellison Flat 44 Rottrill Gardens Marron Place London E8 1NG 01/09/2011 O Mr Nathan Molyneaux Flat 7 Velocity West 5 City Walk Leeds LS11 9BG 18/07/2011 O Sylvia And David Willis Fulmar 4 Meikle Aiden Brae Kilcreggan Helensburgh Argyll And Bute G84 0JD 02/08/2011 O Edna Whyte Gallery House Cullipool Isle Of Luing Oban Argyll PA34 4TX 03/08/2011 O Mrs Astrid Van Der Kraan Glenbeg Kilmelford PA34 4XA 31/07/2011 O Mr Stephen McLaughlin Glencairn Leithen Road Innerleithen EH44 6NJ 18/07/2011 O Mrs Louisa Leader Glencarse House Perth PH2 7LF 24/07/2011 O Mr Hugh Whittle Glenfeochan House Kilmore PA34 4QR 22/08/2011 O
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Mr TJB Sinclair Glenshellach Cnoc A' Challtuinn Clachan Seil Isle Of Seil Oban Argyll And Bute PA34 4TR 26/07/2011 O Mrs Pamela Forsyth Glenview Wyndham Road Innellan PA23 7SH 07/09/2011 O Mr and Mrs D & J Morgan God's House Farm Harts Lane, Ardleigh Colchester CO7 7QQ 04/08/2011 O Mr David Martin Green Acre Halterworth Lane Romsey SO51 9AD 07/09/2011 O P Morris Green Farm Blackberry Lane Coventry CV2 3JS 16/08/2011 O C A Steninger Green Farm Blackberry Lane Coventry CV2 3JS 16/08/2011 O Miss L Monk Greenfield Court Balfron G63 0QG 18/07/2011 O Mr Martin Whitmore Grianan South Cuan Isle of Luing PA34 4TU 05/08/2011 O Mrs Rosalind Whitelaw Grieves Cottage Whitfield West Linton EH46 7AX 17/07/2011 O Mrs Edith Anderson Guisachan House Alma Road Fort William PH33 6HA 02/08/2011 O Mrs Sofie Van Veen Harderwijkerweg 167 Nunspeet 8071 EP 18/07/2011 O N S Hunt Heather Cottage Dove Street Ellastone Ashbourne Derbyshire DE6 2GY 11/10/2011 O Mr Kevin O'Farrell Heir Island Heir Island Skibbereen 1234567 09/09/2011 O Anne Sophie Schipper Hellendoorn The Netherlands 22/08/2011 O Ralph Kempers Hellendoorn The Netherlands 22/08/2011 O Frances Arnold Heugh CLose Stamfordham Northumberland NE18 0NH 12/09/2011 O Mr David Nattrass High Street House Morland Penrith CA10 3AS 18/07/2011 O Ms G Jones Hill of Bandodle Inverurie AB51 7NN 26/07/2011 O
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Mr. Eddie Palmer Hillhead Farmhouse North Mains of KInnettles Forfar Angus 10/09/2011 O Mr Chas Warren Holly Cottage Stanton upon Hine Heath Shrewsbury SY4 4LW 03/08/2011 O Tiery Somer Hollytree Cottage Toberonochy Isle Of Luing Oban Argyll PA34 4UG 19/08/2011 O Mrs Sue Fenton House Plot At The Anchorage Whinbank Clachan Seil PA34 4TW 05/08/2011 O Mr Paul Dix In der Ebene 11 Gerbrunn D-97218 17/07/2011 O Mrs A Van Beckhoven Indigoblauw 4 Zoetermeer 2718jz 18/07/2011 O Mr Luke Alexander Inn at Ardgour Ardgour Fort William PH33 7AA 20/07/2011 O M Breslin Innish Clachan Seil Oban Argyll PA34 4QZ 02/08/2011 O Irene Breslin Innish Clachan Seil Oban PA34 4QZ 02/08/2011 O James And Else Mellor Innishail Clachan Seil Isle Of Seil By Oban PA34 4TJ 01/08/2011 O F Thiller Inshaig House Isle Of Seil Argyll PA34 4RF 26/08/2011 O Mr George Houston Iolair Mhara Acha, Balvicar OBAN PA34 4RJ 27/07/2011 O Drs Walter Vendel Kamperweg 167 Wapenveld 8191 KC 18/07/2011 O Robert Batten Keepeers Cottage South Cuan Isle Of Luing Oban PA34 4TU 03/08/2011 O Mr Ian Tegner Keepers Cottage Kilninver Oban PA34 4UT 16/08/2011 O Mr Ian Tegner Keepers Cottage Kilninver Oban Argyll And Bute PA34 4UT 21/02/2013 O
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F Batten Keepers Cottage South Cuan Oban PA34 4TU 03/08/2011 O Donald N McVean Kennels Cottage Eredine Dalmally Argyll PA33 1BP 01/08/2011 O Mr Thomas Herion Kermelberg 25 Herdecke D-58313 16/04/2012 O The Hon. Michael Shaw Kilbrandon House Balvicar Oban PA34 4RA 28/07/2011 O Dr Angus McCoss Kilbrandon House Balvicar Isle Of Seil Oban Argyll And Bute PA34 4RA 21/02/2013 O T L Nelson Kilmaronaig Connel PA37 1PW 22/08/2011 O Alexandra Nicholson Kilninver House Kilninver Argyll PA34 4UT 07/09/2011 O Rebecca Nicholson Kilninver House Kilninver Argyll PA34 4UT 07/09/2011 O Mr Ewan Kennedy Kinloch Degnish Road Kilmelford PA34 4XD 25/07/2011 O Mr Ewan Kennedy Kinloch Degnish Road Kilmelford PA34 4XD 22/07/2011 O Mr. Donald Hutchison Kinlochlaich House, Appin, PA38 4BD 22/07/2011 O Dr Ian Collins Kirkhill Kippen FK8 3DY 27/07/2011 O Ms Joanne Porter Kirkliston Edinburgh EH29 9AD 26/07/2011 O Mrs Maggie Cole Knowehead Cottage Hightae Lockerbie DG1 1JL 18/07/2011 O Miss Elina Soininen Kokkakatu 4 A 16 Turku 20810 04/08/2011 O Mr. R. Doffer Koningsspil 16 Wieringerwaard, The Netherlands 1766 KV 23/07/2011 O Mrs Jennie Stoop Kruizemunthof 6 Barendrecht 2991HG 30/07/2011 O Mrs Claire Wood La Linnhette Corpach Fort William PH33 7NL 21/07/2011 O Mr Thomas Eeles Little Mill Cottage Great Ashfield Bury St Edmunds IP31 3HJ 23/08/2011 O
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Mrs Shirley Dalziel Little Rahane Farm Rahane Helensburgh G840QW 22/07/2011 O Miss Jan Roylance Llidsey Road Chichester PO20 3SU 23/07/2011 O R M Tapply Loch Caol Cottage Bunessan Isle Of Mull Argyll And Bute PA67 6DX 26/07/2011 O Mr Daniel McArthur Long House Cockermouth CA13 9TG 17/07/2011 O Mrs Elaine Heseltine Carp Lower Leigh Farm, TokesLane East Knoyle SP3 6EY 18/07/2011 O Mr W Taylor Lynn Dee Ganavan Road Oban PA34 5TU 26/07/2011 O Mr Andrew Whitley Macbiehill Farmhouse Lamancha West Linton EH46 7AZ 18/07/2011 O Mr Ludwig Muendlein Maingasse 10 Sommerhausen D-97286 17/07/2011 O Mrs Annette Elgert Maingasse 10 Sommerhausen D-97286 17/07/2011 O Mr T Horrocks Market Hill Georgemas Halkirk KW12 6UU 23/07/2011 O Leonard V McGeoch Master Mariner Rtd Cluain Siar Cullipool Isle Of Luing PA34 4TX 03/08/2011 O Bruce Clayton Merrick Cottage Main Street Forest Hill Oxon OX33 1DZ 03/08/2011 O Mrs Jane Brooke Merricks Farm Langport TA10 0NF 20/07/2011 O Geoff Bisp Millpark House Soroba Road Oban Argyll And Bute PA34 4JF 02/08/2011 O Gillian Bisp Millpark House Soroba Road Oban Argyll And Bute PA34 4JF 03/08/2011 O Miss Cara Naden Millview Thorney Langport TA10 0DR 21/07/2011 O Norman Bissell Mo Dhochaidh 51 Cullipool Isle Of Luing Oban Argyll PA34 4UB 03/08/2011 O
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Dr Stephen Dury Moorfield House The Hill Langport TA10 9PU 18/07/2011 O Dr Marlene Buchy Moorfield House The Hill langport Ta109PU 19/07/2011 O Mr Keith Mac Lean Morvargh Isle of Seil Oban PA34 4TJ 18/07/2011 O Elizabeth C Lyons Morven Cullipool Isle Of Luing Oban PA34 4TX 03/08/2011 O Mr Grant Wastle Nettlebush Drumelzier Place Broughton ML12 6JD 18/07/2011 O Nic Mim No 8 Tinto Place Edinburgh EH6 5FJ 03/08/2011 O C Smith No Address 03/08/2011 O A Henderson No Address Given 02/08/2011 O Anna Beckett No Address Given 21/08/2011 O Barbara Smith No Address Given 01/08/2011 O Catherin Macrae No Address Given 18/08/2011 O Colina MacInnes No Address Given 01/08/2011 O D Windsor No Address Given 14/11/2011 O Dr C J Stevens No Address Given 30/09/2011 O Etonella Christlieb Ouwehand No Address Given 25/07/2011 O Glen Mackie No Address Given 18/08/2011 O Harry Maskell No Address Given 02/09/2011 O J Davies No Address Given 02/08/2011 O J Dickman No Address Given 02/08/2011 O Jean Wolfe No Address Given 02/08/2011 O Keith Rogers No Address Given 03/08/2011 O M E Sandilands No Address Given 01/08/2011 O Monica Haynes No Address Given 02/08/2011 O N Windsor No Address Given 14/11/2011 O Name Illegible No Address Given 04/08/2011 O P E Millward No Address Given 02/08/2011 O Rosie And LJ And M And S Nichols No Address Given 05/08/2011 O Tom Masket No Address Given 02/09/2011 O Zora King No Address Given 04/08/2011 O Alistair Henderson Old Clachan Farmhouse Clachan Seil By Oban PA34 4RH 02/08/2011 O R Henderson Old Clachan Farmhouse Clachan Seil By Oban PA34 4RH 02/08/2011 O Sarah F G Henderson Old Clachan Farmhouse Clachan Seil By Oban PA34 4RH 02/08/2011 O Andrew And Susan Durley Olrig Clachan Seil By Oban Argyll PA34 4TL 03/08/2011 O Mr Barry Deakin Overtheway Godshill Fordingbridge SP6 2JX 01/09/2011 O
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Mr Robin Harvey Penwith Ceum Dhun Righ Benderloch PA37 1ST 02/08/2011 O Miss G J Williams Pintalia Appin Argyll And Bute PA38 4BA 26/07/2011 O Mr Duncan Monteith-Hodge Pole Position Internet Services Ltd 4 George Street Oban Argyll 18/07/2011 O Cynthia Kirpins Prins Bernhardlaan 146M 2032 ZE Haarlem The Netherlands 03/08/2011 O Sebastiaan Koperberg Prinsbernhardlaan 146M 2032 ZE Haarlem Netherlands 03/08/2011 O Master Dylan Inglis Raera Farm Kilninver Oban PA34 4UT 31/08/2011 O Mr James Inglis Raera Farm Kiilninver Oban PA34 4UT 17/08/2011 O Mr Christopher Liversedge Ravenswood Kilmelford PA34 4XD 31/10/2011 O Mrs Karen Liversedge Ravenswood Kilmelford PA34 4XD 30/10/2011 O H Blakeney Reay Cottage Clachan Seil By Oban PA34 4TL 02/08/2011 O Mr David Bridge Redesdale House Skipness Tarbert PA29 6YG 19/07/2011 O Mrs Mary Barnes Rhumore Drimnin By Oban Argyll PA80 5XZ 26/07/2011 O Mrs Marion Brown River Vale 24 Drummie Road Devonside Tillicoultry FK13 6HT 18/07/2011 O Mr Alexander Smart Riverdale, Barran Kilmore Oban PA34 4XR 20/07/2011 O Mrs B Boston Rose Cottage Apeton Church Eaton, Stafford ST20 0AE 26/07/2011 O Mr Roger Wright Rudha Croise Loch Eck Dunoon PA23 8SG 21/07/2011 O Mrs Samantha Jarvis Rye Green Rye Puriton TA7 8BZ 18/07/2011 O Mr Paul Knight Salmon & Trout Association Fishmongers' Hall London EC4R 9EL 18/07/2011 O
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Mrs Elizabeth Ustic School House Lillingstone Dayrell Buckingham MK18 5AP 18/07/2011 O Dr Kevin Butt School of Built and Natural Environment Preston PR1 2HE 18/07/2011 O Mr Andrew Ottaway Seal Protection Action Group PO Box 2673 Lewes BN8 5BZ 25/07/2011 O Mrs Elizabeth Evans Shore Cottage Pirnmill Isle of Arran KA27 8HP 18/07/2011 O Ms Jools Bond South Allington House South Allington Kingsbridge TQ7 2NB 28/07/2011 O Mike Barlow South Cuan Isle Of Luing PA34 4TU 03/08/2011 O Mrs Christine Ferrie Stanton Villa Camus na ha Fort william ph33 7nn 21/07/2011 O Mr Barry Johnson Stonechat Mill Lane, Well Bedale DL82RX 18/11/2011 O Mr Richard Ellis Stoneleigh Thong Lane Netherthong, Holmfirth HD9 3EE 18/07/2011 O Mr Christopher Bromley Stranraer Carlidnack Lane Falmouth TR11 5HE 07/09/2011 O Mr Jeffrey Banks Strathview Station Road Abernethy Perth PH2 9JS 11/09/2011 O Mr Gordon Rothero Stronlonag Glenmassan Dunoon PA23 8RA 22/07/2011 O Mr Anthony Hammock Strumhor Connel Oban PA37 1PJ 20/07/2011 O Mrs Olga Hammock Strumhor Connel Oban PA37 1PJ 17/07/2011 O Mr Michael Barlow Sunnybrae South Cuan, Isle of Luing Oban PA34 4TU 18/07/2011 O Mr. Jack Tempel Swarte Liester 16 Hippolytushoef, the Netheralnds 1777 DT 18/07/2011 O Mrs. Lilian Verheijen Swarte Liester 16 Hippolytushoef, the Netheralnds 1777 DT 18/07/2011 O Mrs. Christine Metcalfe Taigh a Luana Loch Avich Taynuilt PA35 1HJ 10/08/2011 O
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Mrs Caroline Dingwall Tail Farm Fowlis Wester Perth PH7 3NL 21/07/2011 O Ms Carol Williams Tancrey Crieff PH7 4EA 06/09/2011 O Mrs Phylis Malcolm Tapsalteerie Cottage Cullipool Isle Of Luing PA34 4UB 04/08/2011 O Mr Kenneth Campbell The Bank House 10 Main Street Doune FK16 6BJ 01/08/2011 O Mr C D Rose The Bothy Achnaclach Clachan Seil Isle Of Seil Oban Argyll And Bute PA34 4TL 26/07/2011 O Name Illegible The Coach House Ardmaddy By Oban Argyll PA34 4QY 04/08/2011 O Mr Nick Barberton The Cottage woodgreen fordingbridge SP62AR 26/07/2011 O Mr Pol Berguis The Cottage Forteviot Perth PH2 9BT 28/07/2011 O Erin Inglis The Cottage Raera Farm Kilninver Oban Argyll PA34 4UT 10/10/2011 O Jemma Inglis The Cottage Raera Farm Kilninver Oban Argyll PA34 4UT 05/09/2011 O Justin Brooks The Cottage Raera Farm Kilninver Oban Argyll PA34 4UT 05/09/2011 O Ms Syann Van Niftrik The Cottage Woodgreen Fordingbridge Hants 22/07/2011 O Dr Jennifer Joy The Croft Off Haygate Road Wellington, Telford TF1 2BW 08/08/2011 O Mr James Robertson The Four Hollies Barrack Road Comrie PH6 2EQ 25/07/2011 O Mr Alasdair Steele The Haven Clachan Seil Seil Island PA34 4TN 20/07/2011 O
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Douglas Curley The Haven Clachan Seil Oban PA34 4TN 01/08/2011 O Mr Allan Eunson The Mews Torryburn Kintore AB51 0XP 30/08/2012 O Alan Morton The Old Bakehouse High Street Denford Northants NN14 4EQ 22/08/2011 O Heather Morton The Old Bakehouse High Street Denford Northants NN14 4EQ 22/08/2011 O Prof. Hugo Lentmann The Old Boathouse Loch Feochan Oban PA34 4SF 30/07/2011 O A R Wands The Old House Clachan Seil Oban PA34 4TL 02/08/2011 O Hugh Martin The Old House Clachan Seil Oban PA34 4TL 02/08/2011 O Mr Simon Smith The Old Manse Dalriach Road Oban PA34 5JE 02/08/2011 O John Jess And M M MacDonald The Old Post Office 1 Breadalbane Terrace Clachan Seil PA34 4TL 02/08/2011 O Mrs Judy Lawson The Old Rectory Jacobstowe Okehampton EX20 3RQ 19/07/2011 O Mr Henry Middleton The Old Shop Enford Pewsey SN9 6AR 27/08/2011 O Dr Sue Baker The Rookery Rookery Road Blackmore CM4 0LG 18/07/2011 O Mrs Janet Perkins The Roost, Leiston Road Middleton Saxmundham IP17 3NS 02/08/2011 O Mrs Karen Renouf The Shielin Keillour Methven PH1 3RA 20/07/2011 O Mr Bill Jackson The Smithy, Auchnasaul The Smithy, Auchnasaul, by Clachan Seil Oban PA34 4RH 18/07/2011 O Lasta King The Swallows South Cuan Oban Argyll PA34 4TU 04/08/2011 O
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Mr Dave Blackham The Tea Gardens Framilode Passage Saul GL2 7LF 17/07/2011 O Mr Teresa Watts The Tea Gardens Framilode Passage Saul GL2 7LF 17/07/2011 O Mr Charles Clover The Well House High St, Dedham Colchester CO7 6AB 18/07/2011 O Ms Catherine Pendreigh The Whins Ferry Road Tayinloan Argyll PA29 6XQ 20/07/2011 O Mrs Cicely Gill The Yellow Land Whiting Bay Isle of Arran KA27 8PZ 19/07/2011 O Mrs Valerie Bichener Thornloe Guest House Albert Road Oban PA34 5EJ 21/07/2011 O John S C Taylor Tigh Innis Balvicar Bay Isle Of Seil PA34 4TE 02/08/2011 O Mrs Susan Harris Tigh Na Bata Kilmelford Oban PA34 4XA 25/10/2011 O Mr Mark Carter Tigh na Mara Bonawe Oban PA47 1RL 15/07/2011 O Mrs Iris Bell Tir Aluinn Clachan Seil By Oban PA34 4TL 03/08/2011 O Dr Kerry Schofield Tor Cottage South Brent TQ10 9HB 03/08/2011 O Ms Valerie Shakeshaft Tor View South Brent Devon TQ10 9HB 21/07/2011 O Mr Graham Shakeshaft Tor View Wrangaton South Brent Devon TQ10 9HB 29/07/2011 O Mr Nicholas Shakeshaft Tor View Wrangaton South Brent TQ10 9HB 22/07/2011 O Ann Reid Torbeag Clachan Seil Oban Pa34 4TJ 03/08/2011 O Stuart Reid Torbeag Clachan Seil Oban PA34 4TJ 03/08/2011 O E Abrol Torosay Cameron Road Fort William PH33 6LH 16/08/2011 O Mr David Woodhouse Torr Buan house ULva ferry 17/07/2011 O
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Isle of Mull PA73 6LY Mr Mark Struthers Torsa Farmhouse C/O Ardmaddy Castle By Oban PA34 4QY 26/07/2011 O Mr And Mrs J P Colston Traigh Mhor Clachan Seil Isle Of Seil Oban Argyll And Bute PA34 4TJ 26/07/2011 O M Brown Trevelyan College Durham University Durham DH1 3LN 01/09/2011 O Mr Mike Forsyth Trinity Cottage Lempitlaw Kelso TD5 8BN 05/09/2011 O Mr Antony Watkins Tuckers Hill Frog Lane Langport TA10 0NE 09/08/2011 O James Dinsmore Tulloch Beag Kilmelford By Oban Argyll PA34 4XA 27/07/2011 O Mr. Kurt Bourdeaux Vooruitgangsstraat 15 Harelbeke 8530 18/07/2011 O Mrs Carol Sturrock Wedgewood Higher Heath SY13 2HR 04/08/2011 O Dr Alan Pickering Wellbeck Pump lane Springfield, chelmsford Cm1 6ta 05/08/2011 O Mrs Susan Turner Werner-Friedmann-Bogen 38 Munich D-80993 02/08/2011 O Mr Anthony Compson West Street Farmhouse Walsham le Willoows Bury St Edmunds IP31 3AP 31/08/2011 O Ms Johanna Storm Rusu Westcroft House Hebden Bridge Road Oxenhope, Keighley BD22 9QJ 18/07/2011 O Mr John Widdaker Westgate House Milburn Penrith CA10 1TW 27/07/2011 O John And Flora Anderson Westrioch Campbeltown Argyll PA28 6NT 03/08/2011 O Mr John Wilson Willowburn Clachan Seil Oban PA34 4TJ 01/08/2011 O Mrs Alice Wilson Willowburn Clachan Seil Oban PA34 4TJ 01/08/2011 O Ellie Fidler Woodleigh Wood Lane Stanmore Middlesex HA7 4JY 05/08/2011 O
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SUPPORTERS:
Mr Michael Stanford 11B Calton Ave Campbeltown PA28 6NB 20/02/2013 S Mr D Fowler 22 St Clair Way Ardrishaig Lochgilphead PA308FB 14/12/2011 S Mr Ian Armstrong 3 Ardconnel Villa Rockfield Road Oban PA34 5DH 23/01/2013 S Miss Rosa Downing 48 Soldierstown Road Aghalee Craigavon BT 67 0ES 31/07/2011 S Master Corey Choudhury- Reid 76 Crestway London SW15 5DD 03/09/2011 S Mr Robin MacLean Morvargh Clachan Seil By Oban PA34 4TJ 28/07/2011 S Fusion Marine Ltd The Marine Resource Centre Barcaldine By Oban Argyll Scotland PA37 1SE 11/02/2013 S Inverlussa Marine Services Ltd Craignure Isle of Mull PA65 6BD 06/03/13 S
OTHER REPRESENTATIONS:
Mr Glenn King 1 St Marys Close Offton Ipswich IP8 4RZ 22/07/2011 R Mr Joe Kerr West Bank House West Bank Road Ardrishaig PA30 8HB 23/07/2011 R
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APPENDIX B TO APPLICATION 11/01066/MFF
HABITATS REGULATION APPRAISAL – ARGYLL AND BUTE COUNCIL
Date February 2013
Development proposal Relocation of Ardmaddy salmon farm in Seil Sound
Natura site(s) Firth of Lorn Special Area of Conservation
A. INTRODUCTION
This document is a record of the full Habitats Regulation Appraisal, undertaken by Argyll and Bute Council in respect of the above development proposal to assess the implications on the Firth of Lorn Special Area of Conservation.
Planning authorities are advised by Scottish Government not to duplicate the regulatory roles of other regulatory bodies. Had a CAR licence been granted for this development prior to a planning application being submitted, Argyll and Bute Council would not have considered the potential environmental impacts covered by SEPA’s CAR process and SNH would not have advised that an Appropriate Assessment would have been required. Therefore the Council is only undertaking an Appropriate Assessment for this application as the planning process had started prior to the determination of the CAR licence by SEPA.
The focus of the Appropriate Assessment below (see Section 6) is identical to that undertaken by SEPA in their determination of the CAR licence for this application, and relates to aspects of the development proposal which are controlled by SEPA through the CAR licence process. Therefore, the Council have based the assessment and overall conclusions on SEPA’s Ap propriate Assessment which is attached as Annex 1 .
B. PROJECT AND SITE DESCRIPTION
1 Brief descriptio n of the project
The development proposal is to relocate the existing Ardmaddy salmon farm site approximately 900m south within Seil Sound and to increase the maximum licensed biomass from 1300 to 2500 tonnes. In line with an increase in biomass the applicant has applied to SEPA for an increase in the amount of sea lice treatment chemicals that can be discharged. If granted the existing Ardmaddy site will be relinquished.
SEPA have granted a CAR licence for the proposed site for the maximum biomass of 2500 tonnes and an increase in the amount of sea lice treatment chemicals. This CAR licence was granted following the completion of an appropriate assessment, which concluded that the proposal would not have an adverse impact on site integrity of the F irth of Lorn SAC.
2 Relevant natura site(s)
The proposed development is not situated within any European marine sites but is sited approximately 1.8km to the east of the Firth of Lorn Special Area of Conservation.
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3 Qualifying interests for the natu ra site and conservation objectives for each interest
Qualifying interests (see http://jncc.defra.gov.uk/ProtectedSites/SACselection/sac.asp?EUCode=UK0030041 )
The natural heritage interests of the Firth of Lorn SAC for which the site is designated are:
Annex I habitats that are a primary reason for selection of this site: • 1170 Reefs This well-defined, discrete area encompasses a complex group of islands, sounds and inlets characterised by some of the strongest tidal streams in the UK. The area is moderately exposed to wave action with very sheltered pockets enclosed by islands and skerries. Reefs extend from the shallow depths between the islands and mainland into depths of over 200m, in many places close inshore. The varied physical environment is reflected in the variety of reef types and associated communities and species, which are amongst the most diverse in both the UK and Europe. These range from those c haracteristic of conditions sheltered from waves and currents, to those influenced by extreme tidal streams. A rapid transition in communities occurs with the deceleration of the tidal streams. Species present include some which are normally characteristic of deeper water (the sponges Mycale lingua and Clathria barleii , and the featherstar Leptometra celtica ), and others which are considered scarce (including the brown alga Desmarestia dresnayi ). Many species occurring here have either a northern or southern-influenced distribution and reach their geographic limits in this area, for example, the southern cup-coral Caryophyllia inornata , the nationally scarce brittlestar Ophiopsila annulosa , and the northern bryozoans Bugula purpurotincta and Caberea ellisii .
Annex I habitats present as a qualifying feature, but not a primary reason for the selection of this site: • Not applicable.
Annex II species that are a primary reason for the selection of this site: • Not applicable.
Annex II species present as a qualifyi ng feature, but not a primary reason for site selection: • Not applicable.
Conservation Objectives (see http://gateway.snh.gov.uk/sitelink/documentview.jsp?p_pa_code=8256&p_Doc_Type_ID=29 )
To avoid deterioration of the Annex I habitats (listed above) thus ensuring that the integrity of the site is maintained and the site makes an appropriate contribution to achieving favourable conservation status for each of the habitats; and To ensure for the Annex I habitats (listed above) that the following are maintained in the long term: extent of the habitat on site distribution of the habitat within site structure and function of the habitat processes supporting the habitat distribution of typical species of the habitat viability of typical species as components of the habitat no significant disturbance of typical species of the habitat.
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C. IS AN APPROPRIATE ASSESSMENT REQUIRED?
4 Is the proposal directly connected wit h, or necessary to, conservation management of the site?
No.
5 Is the proposal likely to have a significant effect on the site (either alone or in combination with other plans or projects)?
SNH were consulted by the Council as a statutory consultee on the planning application and Environmental Statement for this proposal. SNH advised that the proposal will have a likely significant effect on the qualifying interest of the Firth of Lorn Special Area of Conservation (SAC) and recommended that Argyll and Bute Council undertake an appropriate assessment for the proposal in view of the site’s conservation objectives .
This view was based on the potential of the proposed development to affect the qualifying interest of Firth of Lorn SAC from the deposition o f organic waste and chemo-therapeutants transported into the SAC by tidal currents.
D. APPROPRIATE ASSESSMENT
6 Scope of the Appropriate Assessment
SNH advice is that the Appropriate Assessment should be based on an appraisal of the following: The trans port of organic waste by tidal currents from the proposed development site to it’s eventual resting place or area of dispersal and therefore its effect on the interest of the Firth of Lorn SAC; and The transport of chemo-therapeutants by tidal currents from the proposed development site to their eventual resting place and therefore a resulting effect on the interest of the Firth of Lorn SAC.
The AA should be undertaken in view of the site’s conservation objectives as listed in Part C above.
It is the view of Argyll and Bute Council that the Appropriate Assessment should focus only on the qualifying features of the Firth of Lorn SAC, in this case ‘reef’ habitat , and not on other habitats and species listed under Annex I and II of the Habitats Directive which are not qualifying features of the SAC. This view is in line with SNH’s interpretation of the Habitats Directive.
As the development proposal is out with the Firth of Lorn SAC, potential physical disturbance of qualifying reef habitat from cage anchor s and moorings is not relevant and is therefore not considered further.
7 Elements of development proposal relevant to the scope of the Appropriate Assessment
The following elements of the development proposal are considered relevant to the scope of the AA: • relocation of site in Seil Sound from Ardmaddy, approximately 900m south, to Ardmaddy South; • change in the amounts of in-feed and bath sea lice treatments; and • increased biomass from 1300t to 2500t.
The potential hazards of the development upon the qualifying reef interest are likely to be individually or in combination: (a) smothering, (b) chemical treatments, and (c) cumulative nutrient enhancement. These pressures will be controlled through the CAR licence already granted by SEPA (CAR/L/1099909).
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8 SAC features in the vicinity of the proposal
Both the proposed and existing site are outwith the SAC boundary, however, the proposed site is approximately 300m closer to the nearest part of the SAC boundary at Cuan Sound. The existing site is 2.1km away and the proposed site 1.8km away from the SAC. The existing and proposed cage locations and SAC boundary can be seen in Figure 1 below.
Figure 1. Proposed cage locations (red circles) and SAC boundary for the proposed Ardmaddy South and existing Ardma ddy fish farm sites
Firth of Lorn SAC
Within or near (less than 3km) to the Firth of Lorn SAC there are seven licensed marine fin fish farms producing salmon at Port nan Seannag (Lunga) (CAR/L/1000811), Ardmaddy (CAR/L1010472), Bagh Lachlainn (CAR/L/1025495), Port na C ro (CAR/L/1000810), South West Shuna (CAR/L/1025496), Bagh Dail nan Ceann North & South (CAR/L/1004226), and Ardifuir (CAR/L/1021927). These sites are authorised by SEPA under the Controlled Activity Regulations (CAR) and allowed to use certain listed chem icals for such activities as fish health, net anti -fouling and bio security.
9 Direct and indirect effects on qualifying reef habitat
As discussed in Section 6 above, this Appropriate Assessment focuses on the potential impacts of the development prop osal from: The transport of organic waste by tidal currents from the proposed development site to it’s eventual resting place or area of dispersal and therefore its effect on the interest of the Firth of Lorn SAC; and The transport of chemo-therapeutants b y tidal currents from the proposed development site to their eventual resting place and therefore a resulting effect on the interest of the Firth of Lorn SAC.
Sensitivity of qualifying reef habitat SEPA’s Appropriate Assessment identifies that f ew studies have been undertaken to evaluate the effects
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Page 81 of different levels of solids flux on reef organisms. In terms of the CAR assessment process, the solids flux:ITI relationship has been empirically determined specifically for benthic infauna, and therefore is not directly applicable to reef fauna. However, it is considered likely that some reef fauna will be more sensitive to solids flux.
SEPA’s Appropriate Assessment (see Annex 1 - Section 5 ‘Effects on reef species ’) identifies relevant reef organisms to which AMBI (AZTI Marine Biotic Index) scores have been assigned. The taxa noted from the SAC in the site description (see Section3 above) with AMBI scores assigned, e.g. Dendrodoa grossularia , Corynactis viridis , Caryophylla inornata , Ophiopsila annulosa , all fall into group I of the AMBI scores, identified as species very sensitive to organic enrichment and present under unpolluted conditions.
The MarLIN website www.marlin.ac.uk has assessed available information on the sensitivity of different species and habitats to various anthropogenic factors . Relevant to this assessment are the factors – ‘smothering ’; ‘increase in suspended sediment ’; ‘synthetic compound contamination ’; ‘hydrocarbon contamination ’; and ‘changes in nutrient levels ’. For those species listed in the qualifying interests, no information is available or they are not listed.
Information is however available for the following four types of reef habitat (biotopes) which are likely to be found in th e SAC, and is presented in Table 1 : Antedon spp ., solitary ascidians and fine hydroids on sheltered circalittoral rock (Biotope - CR.LCR.BrAs.AntAsH) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=313&code=2004 Neocrania anomala and Protanthea simplex on very sheltered circalittoral rock (Biotope - CR.LCR.BrAs.NeoPro) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=5&code=2004 Ophiothrix fragilis and/or Ophiocomina nigra beds on slightly tide-swept circalittoral rock or mixed substrata (Biotope - CR.MCR.EcCr.CarSp.Bri) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=278&code=2004 Faunal and algal crusts, Echinus esculentus , sparse Alcyonium digitatum and grazing-tolerant fauna on moderately exposed circalittoral rock (Biotope - CR.MCR.EcCr.FaAlCr.Pom ) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=337&code=2004 .
Table 1 . MarLIN sensitivity information
Assessment details Sensitivi ty information Smothering The biotopes have been MarLIN indicates that the biotopes assessed against CR.LCR.BrAs.AntAsH, CR.LCR.BrAs.NeoPro and smothering by 5cm of CR.MCR.EcCr.CarSp.Bri will have a moderate sensitivity sediment for one month. to smothering, due to their high intolerance but moderate recoverability. The habitat CR.MCR.EcCr.FaAlCr.Pom has an intermediate intolerance to smothering, but a low sensitivity due to its high recoverability. Suspended The biotopes were MarLIN indicates that the above biotopes are not sediment assessed against 100mg/l sensitive or have a very low sensitivity to an increase for one month. in suspended sediment. This is due to their low intolerance and either immediate or very high recoverability. Synthetic For synthetic compounds MarLIN indicates that the biotopes compounds & and hydrocarbon CR.LCR.BrAs.AntAsH and CR.MCR.EcCr.FaAlCr.Pom hydrocarbon contamination, the have a moderate sensitivity to synthetic compound contamination biotopes were assessed contamination, due to a high intolerance but high against mass mortality recoverability. There is insufficient information for the (both short - and long- biotopes CR.LCR.B rAs.NeoPro and term), a reduction in CR.MCR.EcCr.CarSp.Bri, however they are also
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abundances, and sub -lethal expected to show a moderate sensitivity, high effects such as a reduced intolerance and high recoverability. reproductive potential. For hydrocarbon contamination, MarLIN indicates the biotope CR.LCR.BrAs.AntAsH will have a moderate sensitivity, due to a high intolerance but high recoverability. There is insufficient information for the biotope CR.LCR.BrAs.NeoPro, but this is expected to show a similar response to CR.LCR.BrAs.AntAsH. The biotopes R.MCR.EcCr.CarSp.Bri and CR.MCR.EcCr.FaAlCr.Pom are both listed as having a low sensitivity, due to their low or intermediate intolerance and high recoverability. Changes in For changes in nutrient levels, MarLIN indicates the nutrient levels biotopes CR.LCR.BrAs.AntAsH, CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri will have a low sensitivity or are not sensitive, due to a high recoverability and low intolerance. The biotope CR.MCR.EcCr.FaAlCr.Pom will have a moderate sensitivity, due to a high intolerance but high recoverability.
Assessment of effects from solid waste The deposition of waste feed and faecal particles has the potential to smother reef habitat and associated species. SEPA uses the bespoke particle -tracking model AutoDepomod to determine the sea bed deposition footprint of particles leavi ng the cages and also any re-suspension of deposited material to the wider area.
SEPAs Appropriate Assessment has provided a detailed assessment of the impacts from the likely deposition of solids waste within the Firth of Lorn SAC, in relation to qualifying reef habitat. This assessment has been based on the detailed modelling and information considered during their consideration of the CAR licence.
Argyll and Bute Council have reviewed SEPA’s assessment on ‘Solid Flux Impact’ (see Appendix 1 – Section 5) and agree with the summary conclusions set out below.
Summary of solids flux impacts The proposed changes in solids flux may give rise to a likely significant effect. This likely significant effect is due to the predicted export of solids emanating from the proposed fish farm being transported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary (2%).
However, the above assessment leads to the conclusion that the proposal will result in a relatively small (<3%) increase of solids from fish farms in the general area of the SAC. The reported natural sedimentation rates in the SAC are relatively high, and the increase in sedimentation in the SAC, resulting from the proposal, represents 0.00001% of the natural background r ates.
The levels of smothering and sedimentation are negligible compared with those used for the MarLIN sensitivity assessments for relevant reef habitats, and the increase in solids flux over the background levels would not be effectively measurable. This combined with the generally dispersive nature of the SAC and beyond, means it is reasonable to conclude that the proposed changes in solids flux will not give rise to a likely significant effect on the SAC designated features.
This means it is reasonable to conclude that any potential impacts due to changes in solids flux on the SAC designated features will be negligible and will not compromise the site’s Conservation Objectives. This conclusion is based upon the most up-to-date scientific research, and best available rigorous modelling. 6
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Assessment of effects from chemical treatments Sea lice medicine residues, both in the water column and in the sediment, have the potential to be toxic to reef habitat and associated species. The principal materials that may affect sea bed fauna are the sea lice bath treatments azamethiphos, cypermethrin and deltamethrin and the in -feed treatments emamectin benzoate and teflubenzuron. These products are licensed by SEPA for use against sea lice infestations on salmon far ms.
SEPAs Appropriate Assessment has provided a detailed assessment of the impacts from the likely transport of chemotheraputents into the Firth of Lorn SAC, in relation to qualifying reef habitat. This assessment has been based on the detailed modellin g and information considered during their consideration of the CAR licence.
Argyll and Bute Council have reviewed SEPA’s assessment on ‘Toxic effects from sea lice treatments’ (see Appendix 1 – Section 5 ) and agree with SEPAs summary conclusions set out below.
Summary of sea lice treatment impacts The proposed changes in the use of licensed sea lice treatments may give rise to a likely significant effect. The MarLIN sensitivity assessments do not examine the effects of specific sea lice treatments on reefs, but tests on the most sensitive taxa have been used to determine the Environmental Quality Standards (EQS).
For bath treatments, the likely significant effect is due to the treatment plumes dispersing from the proposed fish farm and being transported into the Firth of Lorn SAC, mainly through the Cuan Sound. However, the modelling indicates that the dispersal plumes are not taken directly toward the SAC, and therefore the 0.5km2 mixing zone will not extend into the SAC. This means that bath treatment levels within the SAC will all be below the Environmental Quality Standards (EQS). This combined with the generally dispersive nature of the SAC and beyond, allows the above assessment to lead to the conclusion that any potential impacts resulting from the proposed changes in licensed bath treatments will be negligible and will not compromise the site’s Conservation Objectives. This conclusion is based upon the most up -to date scientific research, and best available rigorous modelling.
For in -feed treatment s, the likely significant effect is due to the predicted export of sea lice treatment residues emanating from the proposed fish farm, being exported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary (2%). However, the above assessment leads to the conclusion that the proposal will result in a very small (<1%) increase of sea lice residues. This amount is not statistically significant (at the 1% or 5% levels), and is well within the margins of error for sampling, analysis and the model. Furthermore, the increase in the SAC is equivalent to 0.03% of the far field Environmental Quality Standard (EQS) of 0.763µg/kg. Such an increase is not effectively measurable, and this combined with the generally dispersive nature of the SAC and beyond, means it is reasonable to conclude that any potential impacts resulting from the proposed changes in licensed in -feed treatments will be negligible and will not compromise the site’s Conservation Objectives. This conclusion is based upon th e most up-to-date scientific research, and best available rigorous modelling.
10 Cumulative effects
Solid waste As discussed in Section 10 above, SEPAs assessment of the effects from deposition of exported solid waste identified that: the increase in so lids exported from the proposed Ardmaddy South site is negligible when compared to the amounts already exported from neighbouring fish farms in the Seil Sound and Sound of Shuna area; any solids exported into the SAC will be widely distributed, both within the SAC and beyond; and the predicted amounts of solids entering the SAC resulting from nearby fish farms are many orders of magnitude below the natural sedimentation rates, and can thus be considered insignificant.
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SEPA’s Appropriate Assessment identifi es that the increase in exported solids represents less than 3% of the total solids exported from all of the fish farms within, or near to the SAC boundary and within Seil Sound and the Sound of Shuna. This increase represents 0.00001% of the natural background sedimentation rates which makes the predicted total sedimentation from the export of solids from all adjacent farms, including the proposed Ardmaddy site, equivalent to less than 0.00033% of the background sedimentation rates. The Council, therefore consider that cumulative deposition of exported solids will be negligible and will not compromise the site’s conservation objectives.
Sea lice treatments Bath treatments As identified in Section 10 above, SEPA modelling indicates that the dispersal plu mes for bath treatments are not taken directly towards the SAC and therefore the 0.5km 2 mixing zone will not extend into the SAC. This means that the levels of bath treatment residues within the SAC will be below SEPA Environmental Quality Standards and t herefore not present a risk to the SAC qualifying features.
The amount of bath treatment chemicals licensed by SEPA for the proposed site is less than that which was consented for the existing Ardmaddy site. As there is no increase in use of bath treatments it is concluded that there can be no cumulative impact resulting from the new proposal.
In -feed treatments The use of in -feed treatments, as licensed by SEPA for the new Ardmaddy site, will result in a very small (<1%) increase in sea lice residue s, which represents 0.03% of the far field Environmental Quality Standard within the SAC . This increase is not statistically significant or effectively measureable and therefore it is considered that the proposed changes in use of licensed sea lice treatments will not result in cumulative impacts on the SAC.
Nutrient enhancement The Scottish Government’s “Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters ” categorise sea lochs, voes and embayments into 3 categories based on predictions of the impacts from the existing scale of development. Models predicting the nutrient enhancement of the water column and the proportion of sea bed likely to be degraded are used to identify areas more likely to be able to support additional farmed fish biomass. Currently, no further increases in maximum biomass are permitted in Category 1 areas. Increases are more lik ely to be permitted in Category 2 and 3 areas (subject to site -specific assessment through EIA and CAR). Neither the Sound of Seil or Loch Shuna have been categorised due to their complex, open nature.
In support of the planning application the applicant provided an assessment of the predicted cumulative nutrient enhancement of the existing and proposed fish farms in Seil Sound and Loch Shuna. The Council has reviewed this assessment and agrees with the estimated ECE value from all fish farms of 13.37 µg/ l.
As advised by SEPA, the estimated input from the existing and proposed farms should be assessed against OSPAR and UKTAG reference or background levels by adding the calculated Equilibrium Concentration Enhancement ( ECE) for all farms in the water bod y to the reference/background level and then the result assessed as to whether it breaches the threshold of 50% above the reference value. Nutrient enhancement calculations according to a Equivalent Concentration Enhancement (ECE) model are described on t he Marine Science Scotland website .
The coastal waters of Seil Sound and Loch Shuna can be classified as ‘Coastal waters’ where Dissolved Inorganic N itrogen (DIN) normalised to a salinity of 32ppt has a reference value of 12µM (168µg/l) and a threshold of 18 µM (252µg/l). Adding the ECE value for all fish farms ( 13.37µg/l) to the reference value (168µg/l) gives a value of 181.37µg/l, which is below the 252µg/l threshold.
It is th erefore considered unlikely that nutrient inputs from this development in combination with other fish farms will have a detrimental effect on water quality or upon primary productivity in Loch Shuna and Seil Sound, in terms of nutrient enhancement. 8
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11 Enforceable conditions on CAR licence which manage the risk of environmental impact, relevant to this Appropriate Assessment
As identified in Section 7 of SEPAs Appropriate Assessment, the CAR licence that has been granted for this development proposal contains site -specific numeric limits for the maximum biomass and sea lice treatments, such that the solids flux and use of sea lice treatments will not be predicted to exceed the modelled Environmental Quality Standards (EQS). Environmental monitoring is built into the licence and enforcement action is taken if these are exceeded.
These limits are there to protect the environment, and their thresholds are set to protect the most sensitive fauna using a well -tried and tested process of EQS setting and additional inbuilt safety factors. SEPA believes that the above will provide appropriate mitigation to help avoid impacts on the site’s integrity with respect to its conservation objectives.
12 Conclusion of Appropriate Assessment
Can it be ascertained beyond reasonable scientific doubt that the proposal will not adversely affect the integrity of the SAC/SPA? The following text, lifted directly from SEPAs appropriate assessment (Annex 1 ) provides a detailed conclusion as to whether the development proposal will affect each conservation objective for the Firth of Lorn SAC. Given that our assessment above ( Section 10 ) has been based on SEPA’s consideration of the CAR licence for this proposal, Argyll and Bute Council have used these conclusions for each conservation objective to form our overall conclusion of the Appropriate Assessment.
Distribution of the habitat within site The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not ex pected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Structure and function of the habitat The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
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Processes supporting the habitat The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicin es are not expected to affect this conservation objective.
Distribution of typical species of the habitat The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this conservation objecti ve. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Viability of typical species as components of the habitat The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, an d thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
No significant disturbance of typical species of the habitat The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
10
Page 87 effects of sea lice medicines are not expected to affect this conservation objective.
Overall Conclusion
As a competent authority, Argyll and Bute Council has undertaken a Habitats Regulations appraisal and appropriate assessment in consultation with SNH and SEPA. This assessment has been based on SEPAs determination of a CAR licence for the development proposal, including their detailed Appropriate Assessment ( Annex 1 ) which is based on high-quality and extensive scientific data.
Having given consideration to the distance of the development proposal to the SAC boundary and qualifying reef habitat; the proposed changes in deposition of solid waste and use of chemical treatments from the existing Ardmaddy site; and cumulative nutrient enhancement, Argyll and Bute Council concl ude that the development proposal will not adversely affect the integrity of the Firth of Lorn SAC, in light of its conservation objectives.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
SEPA’s duties under the Nature Conservation (Scotland) Act 2004 (section 15) and the Conservation Regulations 1994, (Regulati ons 48 and 49) during regulation
Record of the assessment of the conservation implications of fin fish farm activity, in the Firth of Lorn Special Area of Conservation
Licence application number: CAR/L/1099909
Coordinating Officer: Naveed Bhatti, Marine Ecologist Date of completion: 27/04/2012
Page 89 Project and site description
1 Brief description of the project
Within or near (less than 3km) to the Firth of Lorn SAC there are seven licensed marine fin fish farms producing salmon at Port nan Seannag (Lunga) (CAR/L/1000811), Ardmaddy (CAR/L1010472), Bagh Lachlainn (CAR/L/1025495), Port na Cro (CAR/L/1000810), South West Shuna (CAR/L/10 25496), Bagh Dail nan Ceann North & South (CAR/L/1004226), and Ardifuir (CAR/L/1021927). These sites are authorised by SEPA u nder the Controlled Activity Regulations (CAR) and allowed to use certain listed chemicals for such activities as fish health, net anti-fouling and bio security. For example, the farms are licensed to treat outbreaks of sea lice using a selection of chemical treatments, and licensed to use specific amounts depending on many factors such as the size and location of the farm, and number of fish stocked at time of treatment.
Lakeland Marine Farm Ltd. propose to relocate the cages at their Ardmaddy fish farm (CAR/L/1010472) to a new site at Ardmaddy South (CAR/L/1099909) , increase the licensed biomass and sea lice treatment chemicals.
Th e level of authorisation for marine fish farms under the CAR regime is classed as ‘complex’ and the materials have the potent ial to have a significant eff ect upon the SAC, therefore a Habitats Regulations appraisal and appropriate assessment must be made. The potential hazards which can be controlled through the CAR licensing process, either individually or in combination, are (a) smothering, (b) chemical treatme nts and (c) cumulative nutrient enhancement. These only will be addressed below.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
This appropriate assessment updates previous versions of the Firth of Lorn SAC appropriate assessment (including v1 Dec 2005, and v2 Sep 2011) with regard to the Ardmaddy/Ardmaddy South fish farm sites and any cumulative effects. This appropriate assessment considers th e development in relation to the qualifying features and conservation objectives, using information gathered from the site and the most applicable modelling techniques. This information has been collated from SEPA’s own data, as well as that submitted by t he applicant.
2 Special Areas of Conservation or Special Protection Areas within the screening distance of the project
Firth of Lorn, Argyll and Bute
3 Qualifying interests for the SAC/SPA (habitats and/or species) and conservation objectives for each of these interests
The general site character of the Firth of Lorn SAC is: Marine areas. Sea inlets (100%)
Qualifying interests Page 90 (see http://jncc.defra.gov.uk/ProtectedSites/SACselection/sac.asp?EUCode=UK0030041 ) The natural heritage interests of the Firth of Lorn SAC for which the site is designated are:
Annex I habitats that are a primary reason for selection of this site: 1170 Reefs This well-defined, discrete area encompasses a complex group of islands, sounds and inlets characterised by some of the strongest tidal streams in the UK. The area is moderately exposed to wave action with very sheltered pockets enclosed by islands and skerries. Reefs extend from the shallow depths between the islands and mainland into depths of over 200m, in many places close inshore. The varied physical environment is reflected in the variety of reef types and associated communities and species, which are amongst the most diverse in both the UK and Europe. These range from those characteristic of conditions sheltered from waves and currents, to those influenced by extreme tidal streams. A rapid transition in communities occurs with the deceleration of the tidal streams. Species pr esent include some which are normally characteristic of deeper water (the sponges Mycale lingua and Clathria barleii , and the featherstar Leptometra celtica ), and others which are considered scarce (including the brown alga Desmarestia dresnayi ). Many species occurring here have either a northern or southern-influenced distribution and reach their geographic limits in this area, for example, the southern cup-coral Caryophyllia inornata , the nationally scarce brittlestar Ophiopsila annulosa , and the northern bryozoans Bugula purpurotincta and Caberea ellisii .
Annex I habitats present as a qualifying feature, but not a primary reason for the selection of this site: Not applicable.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Annex II species that are a primary reason for the selection of this site: Not applicable.
Annex II species present as a qualifying feature, but not a primary reason for site selection: Not applicable.
Conservation Objectives (see http://gateway.snh.gov.uk/sitelink/documentview.jsp?p_pa_code=8256&p_Doc_Type_ID=29 )
To avoid deterioration of the Annex I habitats (listed above) thus ensuring that the integrity of the site is maintained and the site makes an appropriate
contribution to achieving favourable conservation status for each of the habitats; and Page 91 To ensure for the Annex I habitats (listed above) that the following are maintained in the long term: extent of the habitat on site distribution of the habitat within site structure and function of the habitat processes supporting the habitat distribution of typical species of the habitat viability of typical species as components of the habitat no significant disturbance of typical species of the habitat.
4 Is the proposal directly con nected with, or necessary to, conservation management of the SAC/SPA?
No
Assessment of likely significant effect
5 Identify the individual elements or phases of the overall project that would give rise to a likely significant effect. Clearly identify any element
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
of the project where the scale or magnitude of effect is not known or cannot be determined at this stage.
Proposal Details
Lakeland Marine Farm Ltd proposes to relocate their site in Seil Sound from Ardmaddy, approximately 900m south, to Ardmaddy South change the type of cages from 18 x 24m x 24m x 10m deep cages to 12 x 100m circumference x 15m deep circular cages change the amounts of in-feed sea lice treatments for emamectin benzoate change the amounts of azamethiphos, cypermethrin and deltamethrin bath treatments change the cage surface area from 10,368m 2 to 9549m 2 increase the biomass from 1300t to 2500t the proposed extent of moorings at the new site is 179,800m 2 no change to the species farmed salmon. Page 92 The potential hazards of the develo pment upon the Annex I habitats are likely to be individually or in combination: (a) smothering, (b) chemical treatments, and (c) cumulative nutrient enhancement and benthic impacts. These will be controlled through the CAR licensing p rocess and each is ad dressed separately below:
SAC features in the vicinity of the proposal
Both the proposed and existing sites are outwith the SAC boundary, however, the proposed site is approximately 300m closer to the nearest part of the SAC boundary at Cuan Sound. The existing site is 2.1km away and the proposed site 1.8km away from the SAC. The existing and proposed cage locations and SAC boundary can be seen in Figure 1 below.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Figure 1. Proposed cage locations (red circles) and SAC boundary for the proposed Ardmaddy South and existing Ardmaddy fish farm sites Page 93
Effects on reef species
Few studies have been undertaken to evaluate the effects of different levels of solids flux on reef organisms. The solids flux:ITI relationship has been empirically determine d specifically for benthic infauna, and therefore is not applicable to reef fauna; however, it likely that some reef fauna wi ll be more sensitive to solids flux. This is indicated by those relevant reef organisms to which are assigned AMBI (AZTI Marine Bio tic Index) scores:
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
AMBI scores are assigned as follows [see Borja, A., J. Franco & V. Pérez (2000) A Marine Biotic Index to Establish the Ecological Quality of Soft- Bottom Benthos Within European Estuarine and Coastal Environments. Marine Pollution Bulletin 40 (12) 1100 – 1114]: Group I – Species very sensitive to organic enrichment and present under unpolluted conditions. They include the specialist carnivores and some deposit feeding tubiculous polychaetes. Group II – Species indifferent to enrichment, a lways present in low densities with insignificant variations with time. These included suspension feeders, less selective carnivores and scavengers. Group III – Species tolerant to excess organic matter enrichment. These species may occur under normal cond itions, but their populations are stimulated by organic enrichment. They are surface deposit-feeding species, as tubiculous spionids [polychaetes]. Group IV – Second-order opportunistic species. Mainly small sized polychaetes: subsurface deposit-feeders, such as cirratulids. Group V – First-order opportunistic species. These are deposit feeders, which proliferate in reduced sediments.
The taxa noted from the SAC (see §3 above) with AMBI scores assigned, e.g. Dendrodoa grossularia , Corynactis viridis , Caryophylla inornata , Ophiopsila annulosa , all fall into group I.
The MarLIN website www.marlin.ac.uk has assessed available information on the sensitivity of different species and habitats to various factors, Page 94 including s mothering, increase in suspended sediment, synthetic compound contamination, hydrocarbon contamination and changes in nutrien t levels. For those species listed in the qualifying interests, no information is available or they are not listed. Information is available for four types of reef habitats which are likely to be found in the SAC , namely, Antedon spp., solitary ascidians and fine hydroids on sheltered circalittoral rock CR.LCR.BrAs.AntAsH http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=313&code=2004 Neocrania anomala and Protanthea simplex on very sheltered circalittoral rock CR.LCR.BrAs.NeoPro http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=5&code=2004 Ophiothrix fragilis and/or Ophiocomina nigra beds on slightly tide-swept circalittoral rock or mixed substrata CR.MCR.EcCr.CarSp.Bri http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=278&code=2004 Faunal and algal crusts, Echinus esculentus, sparse Alcyonium digitatum and grazing-tolerant fauna on moderately exposed circali ttoral rock CR.MCR.EcCr.FaAlCr.Pom http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=337&code=2004 .
The habitats have been assessed against s mothering by 5cm of sediment for one month. MarLIN indicates that the habitats CR.LCR.BrAs.AntAsH , CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri will have a moderate sensitivity to smothering, due to their high intolerance but moderate recoverability. The habitat CR.MCR.EcCr.FaAlCr.Pom has an intermediate intolerance to smothering, but a low sensitivity due to its high recoverability.
For suspended sediment , the habitats were assessed against 100mg/l for one month. MarLIN indicates that the above habitats are not sensitive or have a very low sensitivity to an increase in suspended sediment. This is due to their low intolerance and either immediate or very high recoverability.
For synthetic compounds and hydrocarbon contamination, the habitats and species were assessed against mass mortality (both short- and long-term),
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
a reduction in abundances, and sub-lethal effects such as a reduced reproductive potential.
MarLIN indicates that the habitats CR.LCR.BrAs.AntAsH and CR.MCR.EcCr.FaAlCr.Pom have a moderate sensitivity to synthetic compound contamination, due to a high intolerance but high recoverability. There is insufficient information for the habitats CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri , however they are also expected to show a moderate sensitivity, high intolerance and high recoverability.
For hydrocarbon contamination, MarLIN indicates the habitat CR.LCR.BrAs.AntAsH will have a moderate sensitivity, due to a high intolerance but high recoverability . There is insufficient information for the habitat is CR.LCR.BrAs.NeoPro, but this is expected to show a similar response to CR.LCR.BrAs.AntAsH . The habitats CR.MCR.EcCr.CarSp.Bri and CR.MCR.EcCr.FaAlCr.Pom are both listed as having a low sensitivity, due to their low or intermediate intolerance and high recoverability.
For changes in nutrient levels, MarLIN indicates the habitats CR.LCR.BrAs.AntAsH, CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri will have a low sensitivity or are not sensitive, due to a high recoverability and low intolerance. The habitat CR.MCR.EcCr.FaAlCr.Pom will have a moderate sensitivity, due to a high intolerance but high recoverability.
Page 95 a) Receptor: solids flux smothering
The deposition of waste feed and faecal particles has the potential to smother reef habitat and associated species. SEPA uses the bespoke particle - tracking model AutoDepomod to determine the sea bed deposition footprint of particles leaving the cages and also any re -suspension of deposited material to the wider area.
The modelled output of solids flux around the fish farm cage groups are shown in Figure 2 below. The edge of the Allowable Zone of Effect (AZE) is modelled at 192g m-2yr -1, which is equivalent to the 30ITI boundary . This modelling has been produced by the applicant, and subsequently validated, checked and approved by SEPA. More information on the modelling methodology may be found in SEPA’s Fish Farm Manual at http://www.sepa.org.uk/water/water_reg ulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Figure 2. Modelled benthic footprint for solids flux around the Ardmaddy & Ardmaddy S cage groups
Existing licence (Ardmaddy) Proposed application (Ardmaddy S) Depth (m) Flux (g/m2/yr) Depth (m) Flux (g/m2/yr)
100 100 15000 713900 715000 90 90 15000 80 713800 80 714900 70 10000 70 10000 713700 60 714800 60 50 5000 713600 50 5000 714700 40 40 713500 30 1000 30 1000 714600 20 713400 20 714500 10 192 10 192 713300 5 5 714400 Page 96 2 50 713200 2 50 0 0 714300 713100 -4 10 -4 10 714200 -50 713000 -50 -100 1 -100 1 177200 177400 177600 177800 178000 178200 176900 177100 177300 177500 177700
The propo sed site-specific AZE footprint is larger than existing footprint. This is because the proposed site is located in deeper water with r elatively more quiescent conditions. AutoDepomod predicts that approximately 60% of the solids will be exported from the model domain for the proposed site, cf. nearly 100% for the existing site. The proposal will result in a 13% increase of solids exported from the modelled domain (see Table 1 below).
Table 1 . AutoDepomod predictions of solids exported from the fish farm sites
Existing site Proposed site % increase Maximum biomass 1300t 2500t 92 Release of solids 530,824kg 1,020,838kg 92 Export 528,859kg 598,930kg 13 % export 100 59
It is reasonable to assume that t he solids which are not exported, will be subject t o natural degradation processes within the model domain, and so will not affect the SAC or its features. The amount of solids exported is modelled to increase by 70,071kg/yr, the fate of which will be examined in more detail. This increase represents less than 3% of the total solids exported from all the fish farms within, or near to the SAC boundary, and within Seil
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Sound and the Sound of Shuna (i.e. for fish farms at Ardifuir (CAR/L/1021927), Port nan Seannag (Lunga) (CAR/L/1000811), Ardmaddy (CAR/L1010472), Bagh Lachlainn (CAR/L/1025495), Port na Cro (CAR/L/1000810), South West Shuna (CAR/L/1025496), Bagh Dail nan Ceann North & South (CAR/L/1004226), and Shuna Castle Bay (CAR/L/1000801). Note that the two sites in neighbouring Loch Melfort, Eilean Coltair (CAR/L/1000197) and Kames Bay (CAR/L/1000237), have been excluded from the evaluation, due to (i) their distance from the nearest point of the SAC boundary (Kames Bay is 8.1km away, and Eilean Coltair 6.1km), and (ii) their low prospect of increasing the amounts of solids in the wider area as they are in relatively quiescent situations . For example only 0.005% of solids released at Eilean Coltair is expected to be exported from the site.
Natural r ates of deposition in the Firth of Lorn SAC have been investigated by Perry (see Perry (2010) Sedimentation in the Firth of Lorn, Marine Special Area of Conservation (Marine Scotland Science report) see http://www.scotland.gov.uk/Resource/Doc/295194/0107877.pdf [accessed 20/3/12]). The results found that natural sedimentation rates ranged from 1 –60µl/l, but were more typically 2 –13µl/l. The sedimentation rates under neath the fish farm cages (using a flux rate of 10000gm -2yr -1)would equate to less than 1% of the lowest rates observed naturally, and that outside the modelled grid ( using a flux rate of 1gm -2yr -1) would be less than 0.001%. These natural sedimentation rates were measured near the Garvellachs Island groups (Eileach an Naoimh), wh ich is a relatively exposed location, however it does indicate that there are large amounts of suspended sediment being transported naturally within the SAC, and that the hydrographically dynamic environment of the SAC will spread the solids
exported from the fish farm widely. Page 97
Background concentrations are reported to be 5 –10gm -3 [Perry 2010 ibid., see also Dale, A. C. & T. J. Sherwin (2011) Scallop dredging in the Firth of Lorn Marine SAC: modelling of indirect environmental impacts Scottish Natural Heritage Commissioned Report 414 ], which compare to the maximum concentrations underneath the cages of 0.01gm -3 and outside the modelled grid of 0.000001gm -3. It is interesting to note that a recent investigation into the effects of dredging in the Firth of Lor n SAC, found typical maximum concentrations of 0.1gm -3 after one tidal cycle, when the levels of suspended silt in the water column after a simulated dredging event were examined the (Dale & Sherwin 2011).
A report for SARF investigated the exported solids from the fish farms in the Seil Sound and Shuna Sound area (The Fate of Particulate Wastes Arising From Fish Farm Sites (SARF Project 37) see http://www.sarf.org.uk/cms-assets/documents/28813-936945.sarf035---fina1report--- nov07.pdf [accessed 20/3/12]). Modelling results from this predicted that 67% of the solids from the Ardmaddy site would enter the SAC via Cuan Sound and 2% via the southern boundary . If the locations of all the fish farms in the SARF study are compared, it can be reasonably assumed that the Ardmaddy and Ardmaddy South sites will be similar to each other in terms of the proportions of solids exported into the SAC . The high current speeds and dynamic environment in the Cuan Sound and Sound of Luing mean that these solids are not likely to settle within the Cuan Sound or its vicinity, but will be transported more widely within the SAC and beyond. This means that, if for instance all the material exported into the SAC is evenly distributed only within the SAC (and not transported further in the Firth of Lorn), the increase in the sedimentation rate would be 0.2gm -2yr -1 (using 210km 2 for the area of the SAC). Such an increase in sedimentation in the SAC would represent approximately 0.00001% of the observed background levels.
The SARF study also found that AutoDepomod overestimates the amount of solids exported from the model domain, as it does not account for material which was previously exported but which later returns to the model domain. This provides conservatism to the modelled outcomes, and in
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
reality, the amounts of solids from the fish farms in the SAC should be less.
Therefore, i t can be reasonably concluded that the increase in solids exported from the proposed Ardmaddy South site is negligible when compared to the amounts already exported from neighbouring fish farms in the Seil Sound and Sound of Shuna area any solids exported into the SAC will be widely distributed, both within the SAC and beyond the amounts of solids resulting from fish farms in the SAC are many orders of magnitude below the natural sedimentation rates , and can thus be considered insignificant.
Summary of solids flux impacts The proposed changes in solids flux may give rise to a likely significant effect. This likely significant effect is due to the predicted export of solids
emanating from the proposed fish farm being transported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southe rn boundary Page 98 (2%) .
However, the above assessment leads to the conclusion that the proposal will result in a relatively small (<3%) increase of solids from fish farms in the general area of the SAC. The reported natural sedimentation rates in the SAC are relatively high, and the increase in sedimentation in the SAC, resulting from the proposal, represents 0.00001% of the natural background rates.
The levels of smothering and sedimentation are negligible compared with those used for the MarLIN sensitivity assessments for relevant reef habitats, and t he increase in solids flux over the background levels would not be effectively measurable. T his combined with the generally dispersive nature of the SAC and beyond, means it is reasonable to conclude that the proposed changes in solids flux will not give rise to a likely significant effect on the SAC designated features .
This means it is reasonable to conclude that any potential impacts due to changes in solids flux on the SAC designated features will be negligibl e and will not compromise the site’s Conservation Objectives. This conclusion is based upon the most up -to-date scientific research, and best available rigorous modelling.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
b) Receptor: toxic effects from sea lice treatments
Sea lice medicine residu es, both in the water column and in the sediment, have the potential to be toxic to reef habitat and associated species. The principal materials that may affect sea bed fauna ar e the sea lice bath treatments azamethiphos (trade name Salmosan ®), cypermethri n (trade name Excis ®) and deltamethrin (trade name AMX ®), and the in-feed treatments emamectin benzoate (the active ingredient of Slice ®) and teflubenzuron ( the active ingredient of Calicide ®). These products are licensed by SEPA for use against sea lice infestations on salmon farms. Limits are imposed on the amounts of these products licen sed to discharge, and these are calculated using the AutoDepomod model. The limits imposed ensure that the residues arising from amounts of the material used are within S EPA standards set to protect flora and fauna, standards known as Environmental Quality Standards (EQS). These standards are derived from toxicity studies on sensitive organisms, and then a safety factor of between 10 and 100 is then applied.
Hydrogen peroxide (Paramove ®, Salartect ®) is also licensed for used as a sea lice treatment, however, this quickly breaks down into water and oxygen, and is therefore not considered hazardous to marine organisms.
Cypermethrin concentrations in the water column are vir tually non-detectable within an hour of treatment, having no measurable effect on zooplankton, and is thought to have a half life of 35 days in organic marine sediments (2005 SAMS Research Project: PAMP (2005) The Ecological Effects of Sea Page 99 Lice Medicines i n Scottish Sea Lochs ).
These chemicals are not naturally persistent and break down via hydrolysis and photolysis to non -toxic components, though this may vary under different conditions. F or example the half-life of emamectin benzoate in anaerobic sediments is 164 –175 days, whereas photolysis is known to accelerate its breakdown and may reduce the half -life to 0.7 days in seawater. The half-life used for AutoDepomod is 250 days , and so is conservative. [see e.g. McHenery, J.G. and C. M. Mackie (1999). Revised expert report on the potential environmental impacts of emamectin benzoate, formulated as Slice ®, for salmonids. Cordah Report No.: SCH001R5, Schering-Plough Animal Health (2002) Potential environmental impacts of emamectin benzoate, formulated as Slic e ®, for salmonids. Technical Report 36 pp., Bright D. A. and S. Dionne (2005) Use of emamectin benzoate in the Canadian finfish aquaculture industry: a review of environmental fate and effects. UMA Engineering Report for En vironment Canada (accessed on 24 /2/12) http://dsp-psd.pwgsc.gc.ca/Collection/En4-51-2005E.pdf , SEPA Fish Farm Advisory Group (1999) Emamectin Benzoate An Environmental Risk Assessment. 23 pp.]
Bath treatments The p roposed quantities and those for the existing licence, of bath chemical treatments (azamethiphos, cypermethrin and deltamethrin) are shown in Table 2 (below). The amounts of cypermethrin and deltamethrin are slightly higher than previous licensed (both representing ~50% increase). Note, however, that for azamethiphos, the 3hr discharge limit is not used as it would exceed the 24hr limit, thus there will be a 63% decrease for this particular chemical. The amounts licensed previously also used the Environmental Quality Standards (EQS) determined from modelling. The model takes into account the dispersing plumes and the EQS, and the mixing zone is defined as the lower of 0.5km 2 or 2% of the loch area (for more information on the modelling methodology see SEPA’s Fish Farm Manual Annex G at
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http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx ). The proposed amount of azamethiphos is significantly less than that for the existing licence, so this proposal will result in a lower risk of potential impact in the SAC. Cypermethrin and deltamethrin are readily bound to particles, and are rapidly r emoved from the water column. Furthermore, the data from the current meters deployed at the proposed site show that the mixing zone will not be taken directly toward the SAC boundary at Cuan Sound.
Therefore, it is concluded that any potential impacts due bath treatment use within the EQS will be negligible and will not compromise the site’s conservation objectives .
Table 2. Quantities of sea lice bath treatments
Azamethiphos (g) Cypermethrin (g) Deltamethrin (g) 3hr discharge 24hr discharge 3hr discharge 3hr discharge Proposed (Ardmaddy S — 324.3 87.5 65.0 24.4 CAR/L/1099909) Page 100 Existing licence (Ardmaddy — 238.7 236.2 42.8 16.0 CAR/L/1010472)
In -feed treatments The proposed quantities and those for the existing licence, of in -feed chemical treatments (emamectin benzoate and teflubenzuron) are shown in Table 3 (below).
Table 3. Quantities of sea lice in-feed treatments
Emamectin benzoate (g) Total Allowable Quantity Maximum Treatment Quantity Teflubenzuron (g) (TAQ) (MTQ) Proposed (Ardmaddy S — 1654.1 875.0 1358.0 CAR/L/1099909) Existing licence (Ardmaddy — 1245.5 455.0 1351.1 CAR/L/1010472)
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Emamectin benzoate The applicant proposes an increase in the amounts of emamectin benzoate licensed (Table 3). The output plots from the model runs for emame ctin benzoate in the sediments are included below (Fig. 3). The extent and area of the proposed emamectin benzoate footprint is similar to that of the proposed benthic 30ITI AZE ( see Figs. 2, 3).
The far field Environmental Quality Standard (EQS) for emam ectin benzoate is set at 100 times less than the toxicity tests thresholds, and the near field at 10 times less. Therefore, there is some considerable degree of safety built in to the modelled footprint at the near and far fields. These toxicity tests have been based on No Observable Effect Concentrations for studies carried out on the most sensitive species such as Crangon crangon , Nephrops norvegicus , Corophium volutator , Arenicola marina and planktonic copepods. The model predicts higher emamectin benzoate concentrations in the sediments at the cage edge than the standard of 7.63µg/kg (Fig. 3). This is because the near field area is calculated using 7.63µg/kg as the mean value within it.
Page 101
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Figure 3. Modelled benthic footprints for emamectin benzoate residues in sediments around the Ardmaddy & Ardmaddy S cage groups
Existing licence —predicted near-field and far-field AZES Proposed application —predicted near-field and far-field AZES Depth (m) EmBz (mic-g/kg) Depth (m) EmBz (mic-g/kg)
100 100 90 715000 90 713800 80 80 714900 70 713700 70 60 60 714800 713600 50 50 714700 40 713500 40 7.63 30 7.63 30 714600 713400 20 20 714500 10 713300 10 5 5 714400 Page 102 2 713200 2 0 714300 0 713100 -4 -4 714200 -50 713000 -50 -100 -100 0.76 177200 177400 177600 177800 178000 178200 0.76 177000 177200 177400 177600 177800 Existing licence —predicted near-field and far-field AZES Proposed application —predicted near-field and far-field AZES Depth (m) EmBz (mic-g/kg) Depth (m) EmBz (mic-g/kg)
100 100 250.00 250.00 715000 90 90 225.00 713800 225.00 80 80 714900 200.00 200.00 70 713700 70 175.00 175.00 714800 60 60 713600 50 150.00 50 150.00 714700 40 125.00 713500 40 125.00 30 714600 100.00 30 100.00 20 713400 76.30 20 76.30 714500 10 10 50.00 713300 50.00 5 5 714400 25.00 25.00 2 713200 2 7.63 7.63 714300 0 0 713100 -4 0.76 -4 0.76 714200 -50 0.30 713000 -50 0.30 -100 0.10 0.10 177200 177400 177600 177800 178000 178200 177000 177200 177400 177600 177800 -100
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
For the existing Ardmaddy site, the operator returned actual sediment data for emamectin benzoate residues from samples taken in 2010. The sediments values were 0.4µg/kg and 0.6µg/kg at 100m from the cages and 0.6µg/kg at the cage. These results, and those from previous surveys, are all below the cage edge standard of 7.63µg/kg, and below the far field standard of 0.763µg/kg. The samples were collected at the time of maximum excret ion from the fish.
The model permits higher quantities of emamectin benzoate to be used at the proposed Ardmaddy South site due to more residues being retained within the model domain. The licence therefore also limits the amounts of in-feed chemicals acc ording to the amounts exported from the site, and this is assessed for compliance against the far field Environmental Quality Standard (EQS) for 10km 2 (or for 50% of constrained areas) [for more information on the modelling methodology see SEPA’s Fish Farm Manual Annex H at http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx ]. A proportion of e mamectin benzoate residues will therefore be exported from the model grid, in a similar manner to the solids wastes. An estimated 67% of these residues will be exported into the SAC via the Cuan Sound and 2% via the southern boundary (SARF 37 ibid .) and the impact of these residues in the wider SAC will be evaluated in more detail below.
Teflubenzuron Page 103 The applicant proposes a very small increase in the amount of teflubenzuron licensed. The output plots from the model runs for teflubenzuron in the sediments are included below (Fig. 4) (for more information on the modelling methodology see SEPA’s Fish Farm Manual Annex H at http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx ).
The far field and near field Environmental Quality Standards (EQS) for teflubenzuron are set according to toxicity tests thresholds, in a similar manner to emamectin benzoate, and therefore there is some considerable degree of safety built in to the modelled footprint at the near and far fields. These toxicity tests have been based on No Observable Effect Concentrations for studies carried out on t he most sensitive species such as Crangon crangon , Nephrops norvegicus , Corophium volutator , Arenicola marina and planktonic copepods. The cage edge standard is 10mg/kg, and the far field standard 2mg/kg.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Figure 4. Modelled benthic footprints for teflubenzuron residues in sediments around the Ardmaddy & Ardmaddy S cage groups
Existing licence —predicted near-field and far-field AZES Proposed application —predicted near-field and far-field AZES Depth (m) TfBz (mg/kg) Depth (m) TfBz (g/kg)
100 35.00 100 35.00 90 30.00 715000 90 30.00 713800 80 25.00 80 25.00 714900 713700 70 20.00 70 20.00 60 15.00 714800 60 15.00 713600 50 10.00 50 10.00 714700 713500 40 5.00 40 5.00 30 4.00 714600 30 4.00 713400 20 3.00 20 3.00 2.00 714500 713300 10 Page 104 10 2.00 5 1.00 714400 5 1.00 713200 2 0.50 2 0.50 0.10 714300 713100 0 0 0.10 -4 0.00 714200 -4 0.00 713000 -50 0.00 -50 0.00 177000 177200 177400 177600 177800 -100 0.00 177200 177400 177600 177800 178000 178200 -100 0.00
Due to the export of residues from the site, similarly to emamectin benzoate, the model limits the amount of teflubenzuron at both the proposed and existing sites . This means the equivalent treatable biomass is 19.3t for Ardmaddy and 19.4t for Ardmaddy South. The amount of teflubenzuron licensed is therefore not practical for treating the fish, and so it has not been used historically at the Ardmaddy site. No sediment data for tefl ubenzuron residues is therefore available. As only 19.4t of stock can be treated with teflubenzuron at the proposed Ardmaddy South site, its use here is not expected either.
It is therefore reasonable to conclude that there will be no significant impacts in the SAC due to the licensed amounts of teflubenzuron. However, teflubenzuron residues will be exported from the model grid, in a similar manner to the solids wastes and emamectin benzoate, and the impact of this in the wider SAC will be evaluated in more detail below.
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Fate of sea lice in-feed residues in the SAC The changes in the amounts of in -feed sea lice chemicals which will be exported from the modelled grid are shown in Table 4 (below).
Table 4 . AutoDepomod predictions of in-feed residues exported from the fish farm sites
Emamectin benzoate Teflubenzuron Export from Ardmaddy 921.7g 1216.0g Export from Ardmaddy S 929.0g 1220.2g Increase in export 7.3g 4.2g Increase in export 0.8% 0.3%
It can be seen that the relative increase is very small, and below a statistical significance level of 1%. Such a minor chang e is within the margins of error e.g. for sampling, analysis, and the model.
These exported residues may be transported into the SAC, in a similar way to the solids residues. As the licensed quantities for teflubenzuron are too Page 105 small to allow an effective treatment of the stocked fish, only the fate of th e emamectin benzoate residues will be evaluated further. It can be seen that these amounts are very small , and if these increased amounts of emamectin benzoate were spread evenly in the SAC, th is would represent 0.03% of the far field Environmental Quality Standard (EQS) (see Table 5).
Table 5. Fate of emamectin benzoate residues exported into the SAC
Ardmaddy (existing licence) Ardmaddy South (proposal) Increase Export to SAC i 636g 641g 5g Distribution in SAC ii 3.03µg/m 2 3.05µg/m 2 0.02µg/m 2 Proportion of far field EQS iii 3.29% 3.31% 0.03%
i Proportion exported to the SAC is calculated as 69% as per SARF report (The Fate of Particulate Wastes Arising From Fish Farm Sites (SARF Project 37) see http://www.sarf.org.uk/cms -assets/documents/28813-936945.sarf035---fina1report---nov07.pdf [accessed 20/3/12]). Modelling results from this predicted that 67% of the solids from the Ardmaddy site would ente r the SAC via Cuan Sound and 2% via the southern boundary. ii This assumes all residues are retained in the SAC and not distributed further: due to t he strong currents in the Sound of Cuan and Sound of Luing, combined with the low settling rates of the sus pended particles reaching the SAC, mean the residues will be distributed widely and thus fairly evenly distributed in the SAC. (This is conservative as it is likely the residues will be distributed beyond the SAC) . iii The far field Environmental Quality Standard (EQS) is 0.763µg/kg
It is also important to consider the decay of emamectin benzoate residues and metabolites. The half-life in anaerobic sediments is 164 –175 days, but may be as low as 0.7 days in seawater. A recent SEPA survey found a half-life of 58 –93 days for emamectin benzoate, and no metabolites in the
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
sediments —the metabolites appeared to break down even faster. The half-life used for AutoDepomod is 250 days, and so is conservative, therefore, in reality, the amounts in SAC will be signific antly less than those calculated above.
Summary of sea lice treatment impacts The proposed changes in the use of licensed sea lice treatments may give rise to a likely significant effect. The MarLIN sensitivity assessments do not examine the effects of s pecific sea lice treatments on reefs, but tests on the most sensitive taxa have been used to determine the Environmental Quality Standard s (EQS).
For bath treatments, t he likely significant effect is due to the treatment plumes dispersing from the proposed fish farm and being transported into the Firth of Lorn SAC , mainly through the Cuan Sound. However, the modelling indicates that the dispersal plumes are not taken directly toward the SAC, and th erefore the 0.5km 2 mixing zone will not extend into the SAC. This means that bath treatment levels within the SAC will all be below the Environmental Quality Standard s (EQS). This combined with the generally dispersive nature of the SAC and beyond, allows the above assessment to
lead to the conclusion that the proposed changes in licensed bath treatments will not give rise to a likely significant effect on the SAC designated Page 106 features .
For in -feed treatments, the likely significant effect is due to the predicted export of sea lice treatment residues emanating from the proposed fish farm, being exported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary (2%). However, the above assessment leads to the conclusion that the proposal will result in a very small (<1%) increase of sea l ice residues. This amount is not statistically significant (at the 1% or 5% levels), and is well within the margins of error for sampling, analysis and the model. Furthermore, the increase in the SAC is equivalent to 0.03% of the far field Environmental Quality Standard (EQS) of 0.763µg/kg. Such an increase is not effectively measurable, and this combined with the generally dispersive nature of the SAC and beyond, means it is reasonable to conclude that the proposed changes in sea lice t reatments will not g ive rise to a likely significant effect on the SAC designated features.
This means it is reasonable to conclude that any potential impacts due to the use of licensed sea lice treatments will be negligible and will not compromise the site’s Conservation Ob jectives. This conclusion is based upon the most up-to-date scientific research, and best available rigorous modelling.
6 Identify any likely direct, indirect or secondary impacts of the project, in combination with other plans or projects, on the SAC/SPA.
c) Receptor: cumulative effects
Cumulative effects due to an increased biomass on the water quality and nutrient status may occur. Currently the sole means of determining carrying capacity for fish farms in a waterbody is by use of the Locational Guid elines. The existing Ardmaddy and proposed Ardmaddy South fish farm sites are not within a SEERAD Category area. This means the area has sufficient flushing to dilute and disperse the chemicals released from the fish farms such that, taken in combination, they do not breach Environmental Quality Standards (EQS). Any changes to cumulative effects due to the proposal
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
are therefore considered negligible.
7 Identify standard conditions within the authorisation, or other conditions agreed with the applicant, which will remove the risk of likely significant effects listed above.
The CAR licence for the fish farm contains site -specific numeric limits for the maximum biomass such that the solids flux will not be predicted to exceed the modelled Environmental Quality Standards (EQS). Environmental monitoring is built into the licence and enforcement action is taken if these are exceeded.
The CAR licence also contains site -specific numeric limits for sea lice treatments such that their authorised use will not be pr edicted to exceed EQS. Environmental monitoring built into the licence will pick up residues of treatments and enforcement action is taken if these are exceeded.
8 List any remaining likely significant effects, or identify those for which it is not possible to determine that there is no likely significant effect.
Page 107
Conclusion of assessment of likely significant effect
9 Is the plan/project likely to have a significant effect on the SAC/SPA, either alone or in combination, with other plans or p rojects?
No
Appropriate Assessment
10 Identify the relevant conservation objectives to consider for the SAC/SPA.
The Annex I habitat of the Firth of Lorn SAC which will be affected by marine fish farm operations is reefs.
The relevant conservation objectives are: To avoid deterioration of the Annex I habitat ( reefs) thus ensuring that the integrity of the site is maintained and the site makes an appropriate contribution to achieving favourable conservation status for each of the habitats; and To ensure for t he Annex I habitat (reefs) that the following are maintained in the long term: distribution of the habitat within site structure and function of the habitat
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
processes supporting the habitat distribution of typical species of the habitat viability of typical species as components of the habitat no significant disturbance of typical species of the habitat.
11 Identify any enforceable conditions agreed with the applicant, which will remove the risk of likely significant effect from the elements of the project l isted above.
The numeric conditions placed within SEPA’s CAR licences are robust and enforceable. SEPA will act upon evidence and data sug gesting that numeric limits have been breached. These limits are not negotiable with the applicant as they are there to protect the environment, and their thresholds are set to protect the most sensitive fauna using a well -tried and tested process of Environmental Quality Standards (EQS) setting and additional inbuilt safety factors. SEPA believes that the above will pr ovide appropriate mitigation to help avoid impacts on the site’s integrity with respect to its conservation objectives. Page 108 12 List any remaining likely significant effects, or identify those for which it is not possible to determine that there is no l ikely significant effect.
Conclusion of Appropriate Assessment
13 Can it be ascertained beyond reasonable scientific doubt that the proposal will not adversely affect the integrity of the SAC /SPA?
The conclusion of the assessment of likely significant effe ct is that there will be no likely significant effect. However, SNH have advised that an appropriate assessment should be undertaken as part of this Habitats Regulations appraisal, and this should consider each of the relevant conservation objectives, just ifying why each is maintained.
Distribution of the habitat within site: The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. The proposed use of sea lice bath treatments will not result in any exceedance of the E nvironmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not e xpected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Structure and function of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Processes supporting the habitat: the proposal will result in changes in solids fl ux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. Page 109 The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) i n the SAC. The modelling indicates that the dispersal plumes will not extend into t he SAC, and thus the effects of bath treatments are not expected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Distribution of typical species of the habitat : the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in th e SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not e xpected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Viability of typical species as components of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling,
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ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC April 2012
and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. The proposed use of sea lice bath treat ments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not e xpected to affect this conservation objective. The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
No significant disturbance of typical species of the habitat: the proposal will result in changes in sol ids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective. The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) i n the SAC. The modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective. Page 110 The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
The refore the distance of the site to the SAC boundary, and any potential designated features, in combination with the proposed changes in solids flux, chemical treatments and cumulative nutrient enhancement (as evaluated above), lead to the conclusion:
there will b e no adverse effect on the SAC site integrity .
As a competent authority, SEPA has und ertaken a Habitats Regulations appraisal and appropriate assessment. This assessment has been based on high -quality and extensive scientific data, and uses the latest available information. A rigorous scientific conclusion may therefore be reached.
Therefore, i n the view of SEPA, and in consultation with SNH, impacts from solids flux, sea lice treatments and nutrients are calculable and will not have an adverse effect on the SAC features or conservation interests of the site.
Page 22 of 22 176200 176800 Page177400 111 178000 178600 and Boulders
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Rock Ardfad The BieldCamusbeag Low Mean Drain 5.2mIssues FarmhouseOld Clachan 19.8m Bould ers Collects Barnafeochag Ar Baile T ra ig h M h o r Quarry(disused) 13.1m Mud &Sand Fiyorn FB Clachan F arm MLWS Track Mud andShingle Willowburn Hotel Shingle Seil Sound Marsh Drain Cnoc-uaine Eile an àn-leacB Springs Cairn ClachnaSula 6.7m Track MeanHigh Water A c h n a s e ila ch
ingle Clachan Seil Rock Drain 59m
MHWS MLWS Rock Sh & Sand Innishail MHWS
Drain MLWS 9.4m Rock Track FB
MH W Lodge Springs Mud &Shin gle Mud andShingle Torbeag 19.8mMP Rock Mean High Water Mud FBDrain Spring
S & M LWS 14.0m MLWS 1 Whin Bank Gl 59m
en Mud 4 Issues Drain Mean High Water Springs MHWS Shingle 16.5m B 844 Lecki e Ga ll MHWS FB ain 66m Boulders & Mud Camuslaic h BouldersScattered & Shingle MLW T h e S ta bB leLB s844 67m Mud FB 844 B MLWSRock The Smithy B 844 GP 13.1m
Mu dMH W S h in gMLWS le & B MHWMLWS FB FBPond
4m Mud Taig na Fasgadh oluders FB 69m Rock S MHWS Craig FB Drain MLW Collects TighGlenalbyn na Rock ois gte WS 4mNTL Sith MHWS Waterfall MH MLW 3 Auchnasaul Farm Hazel 1 SeilBracken IslandShingle Cotts MLWS 17m CreagL DruimBuid he Rocks Shingle
CottagesRowantree 1 ck Craigard 4 TighCladaich Pit(disused) Rubha Sasunnaich WS Tra Drain 1 Shingle MLW ML Burnside St Clair NTL Glen Ga lla in
Sou nd o f Insh Track 5 Seil
TCB11 Nurse's Cottage Rocks 95m
10 AchnanclachThe Bothy Rock iche Eagla 75m Aroara 14 Rocks t A 168 Loch Caithlim Glenshellach Carreig Tigh naRos Bhain Water Springs All (T) (Tid al Pond) 10m Ardchorra TighOisean Air Low Mean
Rock Dun MhorEas Cruachan 10.7m Lochan Riv
High Pastures Creagan Tigh- Shingle a' Bhain ne er Pond Shuna HazelMount Jetty nd Spri ngs Low Water Boulders Mean & Shingle Ga lla in Laggan-a n-airgid Waterfall CruachScarba Dunvegan Heatherlea Sou Seil Seil Achasia Mingulay Springs Springs Water High Mean Lochan na Slo c Track 7.3m Water Sinks h-Airi gh 106m nan Uan Track Dorus Mor High Mean Shingle Sheep B 844 B Issues
Reay CottageReay Shingle An-Fhuaran TCB Jetty
21 Terrace ane Shingle MLW Tom a ' Quarr y MLWS 13.7m Strathnaver Breadalb Rock (disused)Pit Chruachain (dis used) Slo ca n Eic h 8.5m Jetty Dhuin n Track Ardshella ch
Slo c n Drain Oban Sei lFarm an Seil Shingle Rock Shingle GlenRis d ale S ga rbh Slo 31.1m MeanMean Low Rock Shingle c a ' B
Roc k 29.9m HighWater Water MLWS Mud
hi ora in Springs Jetty Springs Rock Path (um) Path CottageAlma Shingle MHWS Bould ers Sei l The Haven 19.5m
BhiorainCreag a' 40.8m S h in g le & B Rock Shingle Meall nan
Carnan oulders Tarmachan WS ML Cai rnban Pond Keno Hill Callanish Olrig DùnDubha ich Am Bioran 33.8m Track Sheepfol d
Rock ArdmaddyView Tigh CaoraichNa Achraich Drain MHWS Slo ca n MullView Oban Seil Drain Boulders MLWS Rowanbank Sheep Pond
t-Siomai n MHWS& Shingle Wash Rock and Bould ers CroftCottage B 844 MLWS
Old Crofthouse 11.9m MLWSML Boulders & Rock MHWS Rock Issues CroftOban Seil Oban Seil CottageRock WS Pond Lochan Dùn MLWS Issues Issues CrofthouseThe Pond Dubhaic h Rocks a'Meall Chàise Track Pond Sgeir Liath Rock 123m Issues 6.4m Finlaggan SeabankCottage Surgery Rock & Shingleand Lochan na Mast MLWS Rock Florida Seil Haven Shi ngle Garbh-bheinne Rocks Shingle Seil Seil Grange Seil Creag Water
im Sound of Insh Springs Issues Track 127m Water it hl Mutiara Rock RockRock Mean Low Water SpriHigh Mean ngs Ca Rock Sinks Issues Jetty Cave ColmanUamhnan Shingle R o c k & S hin g le
7.9m Buolders R o c k & S hin g le Rock s Rock Track ingle & Boulder Bo 132m B 844 Rockingle & Sh Sh & Rock Mud, Sand uld er s 48m ingle
MHWS Rock & Sh MSprings e a n H ig h W a te r
Carraig Carraig Lùibena MLWS Track MHWS Burn le le
Seil Rock Rock & Shingle Rock Barnayarry ingle da DùnMòr Burn Track Rock & Sh Rocks Barr Aill eLodge 131m MLWS Distillery Drain MeanWater Low MLWS Rock n Ris Track Springs MLWS Gle
Rubha Mhic Reservoir Mud &Boulders Bou
ld Mharcui s MLWSRock Rock MLWS MHWS Rock Sgeir Liath-bheag Pond Water
ers MHWS Caolas DùnDiomhanais Seil Drain WS in
MLWS Rock Beacon Track MLWS Rock ML 35m Dra
Shingle Rock Shingle ParkCar CaolasCott ages 12 MhorGarragh Tigh-An-DuinBraehouse Inshaig House le WS Sgeir a' Gheoidh Shingle Mean High Hinba Hillbrae Mhuilinn a' Allt MH MLWSRock Buoy Rock W a te61 64 r S p rin g s The Old 5.8m LB 8m Shing Craig Ulian g ngs ai MHWS MeanLowShingle CottageCaladh EngineeringWorks The Cottage Shingle An-Calla Drain Seil Sound FB Water Spri Water t Dall erm Mean Low LowMean MHWS WMHWS aRock te r S p r ing sPuttingGreen Water Sinks An Grianan All
Rock Landing StageShingle 4.0m Mud Rock Rock MeanWater High Spri ngs Easdale Sound SM TCB 1 Seil Island Hall S h in g le & S SchoolPrimaryEasdale Path (um) MLWS PH 13LB 15 7 c a tte r e dWater Bo u ld e r s An IEala sean Rock MHWS SgeirLiath-mhòr Tk RockPCCottHarbour Brewery Cottage27 IslesMisty 2930 18 12 4.3m Water Atlantic House Rock Sheepfol d
Shingle Sgeir nam Ban heritageentre3132 c 24 3436 T ra1 m w a y C otta g e s Rock 130m ) S
8
Shingle MLWS 33 38 37 4 Drain MLWS
Water Shingle (F Ferry Shingle Playing Fie ld Shingle Cnoc- Fennaig House Rock s t Blà ran Ferry 42 39 8.5m MHW Rock All
Springs Track ShingleMLWS Rock 41 39a Path (um)Ell enabeic h Track Bould ers MeanLow Water Rock uld er llermaig
MLWS Rock Springs and Mud MLWS Bo Da Water BàrrAille DW Water MLWS Pier(disused) MHWS MHWS Shingle Mean High DWs El Sub Sta Balvic ar &Rock Shingle Easdale Eileanan anMHWS U Shingle Slipway Mean Low ngs Dun Aorain Shingle Coach TheHouse Bay Rock Water Water SpriWater Spri ngs DW Water Track 55 Shingle Rubh' a' ChruidMean h Beacon High ShingleMeanMean Low Low HouseDunearn DunmoreAnnexe Cla chandubh 32m Cai rn
Shingle Shingle ShingleSprings Rock MLWS Rock MHWS Pond MP MeanMud &Sand High 50
MLWS 49 Mo Dhachai dh LBTCBSlipway 59 WaterShingle SpriRock R o c k &Sh Schiehallion inB g 844 le Dunmor House The Lodge Golf Course Water Spri ngs Pond Cnoc Cùl ngs
45 MLWS 57 (PH)The Pufferool FerryHouse 44 Eilean T ornal Rock nan Uamh
Rock &RockShingle El SubSta Shingle Track 8 HallThe100 Old Sch 1a1b 63 65 SgeirMòr-fhir 35.7m 8 B NTL FB
62 60
10 38 3 2
Shingle 41 2324 GreinnachTigh Stone MHWSEasdale MHWS Dunaverty8.5m B 844 GeographiIndicator cal B 844 MLWS
Rock &RockShingle Shingle Water 4037 20 22Stones Throw CottageT h e S h5 ieMHWS lin g Shingle Shingle Rock 844 B MS 6m MLWS Boulders & Mud MLWS
Briar CottBriar Track331831153216 11c12 MHWS RMHWS o c k & S hin g le MHWSDW MHWS MHWS &ShingleRock Sgeir na Faing MLWSRock Shingle Mean W a teHigh r S p rin g sTigh Beag 14B14a13 Museum &RockShingle MLWS Track LB TCB Golf Course Mud Mud Rock Ardmaddy L odge FiaAth cla ch Rock Easdale Shingle 2913b Easdale ingle CottageBrandon DubhClachan FB PO Shingle Shingle Slipway &ShingleRock 131m Shingle &Rock Shingle An Lionadh Water High Mean Springs ShWater & Rock ShingleShingle Mhuilinn a' Allt Path (um) 2.1m ClachandubhLodge HouseBalvicar 10 Tigh Innis MLWSRocks Pier Rock Boulders
101 Rock & 44.8m Ashburton Spreads House 1 MHWS Ford Cnoc nan Springs Shingle Low Water Low Mean MLWS Rock B 844 35 5 Feorlin Oronsay LodgeCoquet BruachAm ShingleMLW MLWSRock Waterngs Spri Làrach-cloi che Rock & Shingle & Rock Mean Low Rock Port a'Mhuilinn 5.8mSEAVIEW1 12.5m 844 B An Tigh Garalapin36 11 Tigh Ian Rock PubuillUamh Barrnacoil ich
RubhaFaoileann n am Rock Shingle TERRACEChapel(site of) Dunmarrock House 4.9m ClachandubhFarm Tulloch Ard AirTir Rock (Cave)
Camas MòrCamas MLWS MHWS RuadhCarraig Shingle An Grianan 40.2m 8003 B Camelot5 16 Balvi car CollCottage Earn Rock
8 20 1
MHWS Pond 2 MhòrCnoc Beag 9 10Ardseil Boat Yard Rock
23 22
Collects 1 Pond Well 17 Barchailein The Grave
BelnahuaThe OldManse Druima 'Chladha 29.9m Drain Pond Club Hous e 25 Boathouse &BouldersShingle Cruach Rarey
Bogha ClèiteBogha WarMemorial 29 8 7 Rock Seileachan 6 Pond 5 nan Rubha Ròn
Shingle 32.6m Kilbride Kilbrandon Track T'hule Beannachd 4 Kilbrandon Collects ings
Sgeir Breine Phuirt RockMHWS MLWS BreinePhort Track 9.8m (remainsChapel of ) 8 Cnoc Mhor Drain 1 Cottages ngs Spri Water 122m
Rocks CoastalSlope Tank 17.4m Graveyard Spr Water High Low Mean Mean
CoastalSlopeTrack KilbrideFarm Track The Former Manse Golf Course Shingle
Springs Slag HeapTrack Cave (disused)Quarry GridCattle & Boulders Path (um) Water Low Water Spri ngs 8.2mCemetery Pond Pond ermaig
Mean High Mean Track Shingle ForrestCottage CottaArran ge Allt Dall Creag
Sgeir an CottageKilbride Drain Shingle & Boulders Tra ck nan Cuil ean Fhairchi n MHWS KilbrideCroft Seil & Boulders Seil Sound Jetty Craiguillean Sheepfol d Seil Pond Cottage The Coach The BothyHo
RockMLWS & Track MeanMean Low High TennisCourt
MLWS Rock Shingle MLWS Rock & Shingle CroftAchnacrois h11.6m Fort WaterShingleW aTrack teSpri r S p r ing s Ardmaddy Castle LeumUille im
Balvicar ngs Eas ck n Rocks Cave Ponds Issues Tra an Cruach na Ce MLWS Rock Meall Donn RockMLWS Rock StrongormCottage Rock ar Cabai g MLWS Rock Tian Cnoc gheMhòirfort CottageAchnacrois h Strongorm Farm Mud &Shin gle Sinks Pond da Winterton MLW ch Ford 123m
Shingle (um) Path Cluanie Issues MLWS Drain Waterfall
Drain CG Mean High Tra ck
Rock Port Sei lisdeir Shingle Water Path (um) FB Jetty Springs NTL Sewage Waterfall Weir Oude
Pond &BouldersShingle MLW Drain Works GridCattle Waterfall Dam Drain TighRycroft Rannic h Scarba MullSeil ChaletsBalvicar Track MLWNTL E a s n a n C e a r d ach Coll Rock MLW Waterfalls
Drain Track Acha Drain Drain Iona Luing Easdale Ullinish Shingle MLW Waterfall MS nn Drain Shingle ui Shingle &Rock 11.6m Cattery &Shingle Mud Shingle Mud Ardmaddy Bay Shingle ars HamnavoeIolair & Boulders Track T 123m
MHWS An Corran Mhara Drain MHWS Eas
Ardlussa Shingle Boulders &
Tigh a'Ghlinne Shingle Loch nan MLWS &RockShingle CorrievrechanC r a ig eTigh naFair n e y a r ry Pit(disused) Mud Burn Ceann
& &RockShingle Rock 8003 B Zanadu MHWS Rock MHWS Mud MH Marble Rock& Mud &Shin gle MudWS Mud Shingle Drain (T) Rock &RockShingle Pond 16 Henderson's Rock Mòr Bàrr Drain Mòr Port Marsh Rock Oud e 8 A Rock Shingle Mud Caddl eton
MHWS 8003 B FarmBalvicar Track Mulla ch an Dam MLWS 16.8m Issues Mud &Shingle Shingle WS t-Socaic h MHWS Rock Rock ML Shingle Drain Dam Pond Shingle ShingleWater Spri ngs Track MLWS &RockShingle Drain MudMean &Sand High Old Eas n Shingle Drain Rock Marbl eQuarr y Tra ck an d Bould d ers Ce Drain Sheepfold Springs Waterfall ar da ch Lag nan Cruach SeilBalvicar Drain Rock Water Ardmaddy Bay Cnoc naMòine Dam Slu ice Drain Shingle High Mean nanLochan Ceardach Pat h
Collects 34.7m ngs Spri Water Shingle an Ford SM 133m Path (um) Springs Rock RockLow Mean
MLWS Drain Rubha n aGaoit he Water Ma rbl e B Track Rock Pie r ck
Rock & Shingle Rock High Mean ngs Jet ty ur Tra n Collects Braeview Spri Water ck Loch na
ae pings Spri & Shingle Rock Water Church o fScotlandKilbrandonandKilchattan Sinks Pond Low Mean Tra Cruai ch
Mean Low Mean Shingle Rock 142m
Seil Collects Braefoot Sheepfold WS
Shingle MLWS MH Tk 138m Mud Mud Water de Water Spri ngs Water Rock Shingle Dun Mucai g HouseKilbrandon &RockShingle Rock ille Ou
Sgeir nam Faoileann MLWSHigh Mean Ponds Well Seil Sound o Tra ck Cnoc an
Rock MHWSMLWS (remainsChapel of ) Rock Marsh Tra C Riv er Laoig h ck MLWSShingle Track Rock MHWS Be FB An Socach ck
Rock Port nam ala Tra Faoile ann MLWS ShinglePond Rock Shingle ch Ga the oi Barr n a
Ballachuan Loch Springs &RockShingle Shingle s of Melfort 122m Loch
Rock &RockShingle MLWS Shingle BoatHouse Water Springs MHWS Rock and Boulders ui m Pas Rock FB MLW Mean HighLow Mean Water Rock Dr Che all ai r ingle ngs Rocks &RockShingle Pond MLW MLW Rock &MLW Sh Rock MHWSSpri Water à'ChomhraidhEilean
NTL MLWSHigh Mean 42.1m Rock Wis hin g MHWS Shingle Tree nam CruachF earna MLWS Mòr Port 103m
ae pings Spri Rock Water Mean Low Mean 332m Rock Boulders
MLWS Shingle Rock Quarr y A 8 16 (T) MLWS 31.7m MS
Rock 8003 B MLWS MHWS 87m Dubh-fhèit h MH W A 816 Issues S Ponds Cruach an Nid
ML WS Sheepfold 32.9m Rock Ballachuan House AnSìdhean Track Track
R o c k & S hin g le Ballachuan Track Issues Track Sheepfold 74.4m Pond Farm Boulders Drain Track 51.2m Magazin eWood Weir Be Cave Pump House Buoy Cuan Poin t 21.9m ala Track Rock Bould ers ch Ga rb h 'a C ho MLWS 22.2m Track (um) Path 35.7m Rock Rubhana Mò ine Track Line Pipe
Seil Track 6 Collects Path (um) Oude River Lay-byDrain ire ingle 17.4m Rock 10 115 FB 57.9m WS
Ponds Sh Cuan ML 1 Mews nne Culanach Cottages Rock Hazelwood ParkHorse Path (um) S MLWS C a ttle g r id W MLWS Burial Cottage 57.3m Srònna F ei Rock Pond Pond R o c k & S hinCalderwood g le North Cuan Croft MH Rock Drain Ground Pipe Line
ETL Cuan House KildaltonCottage 3 2 Tra ck Kil choan L ochs Creag F earna FB Pond IssuesCistern (um) PowerStationPath Track
Rock Ferry 1 Sheepfold Ford Sinks dh Sh ing of T Cottages MLWS Track
Rock Rocks le ra mwTra ay Shingle Dunfillan Path 17.7m
ck Cuan Sound MeanWater High MLWSSpri ngsLB Collects Shingle Collects
WaterMean LowPier 8003 PCB Collects
Sgeir na h-Airei g Rock Springs Rock Muirlan Creagan F harai Pat in Creag HerringInn The Shower(PH) of Tank Path (um) WS Slipway Torr Dhamh h Dra an Stùrra Glenfearnach Melfort House Fi rt h o f Lor n ML Port Mary MHWS Clacharan Port anDuine Mhairbh Dun An Coire Putting Green T e n n is C o urt
andBo Cuan Ard Cuan Cottage Rock WS S hinuld gl e er Jetty ML 56.1m s ETL The Moorin gs Melfort Druimnean n
Shi ngle Shingle Spri ngs Water Low Mean Bould ers FearnachHouseBay PierCottages na Loch Rock Shingle Pond Pond Track Issues TCB BoatHouse de 5.8m Track Collects Quarr y Shi ngle ngs R o c k & S hin g le RockMHWS Am F aradh Issues Dra Pond MHWS Slipway Drain LB Ou River in alaraois ch a' Rock (dis ) Cnoc na Luing Slipway MeanShingleWater Spri High MLWS Rock Rock Kil choan L ochs Be Ch Dam ShingleS c a& tte r e d Bo u ld e r s NTL Track Pond h-Earde LB HoFerry Fearnoch Rock MLWS MHWSSM SM 3.0m Waterfall s 1 to 3 to 1 K e eTCB p e r s C ott Rock Tra ck Drain Ford SM SM SlipwayShingle MHWS Drain
Track Shingle Seil Sound MLWSSlipway BouldersShingle &Scattered MLWS Sinks Sinks
Cliff Cottage Quarry(disused) anCamas Albannaich Eile an n ah -Eaglais e Tra ck Pier MLWS Track Track
Shi ngle Sunnybrae Rhuba Breac Issues MLWS MLWS FearnachHouse FearnachCottage 816 A Sta cn a le
Shingle Morai n Shingle and Bould ers Collects hailli ch h ing Shingle (Natural Arch) Shingle MLWS Rock Issues Path (um) Sluice n F Shingle &Scattered Boulders Track 54.9m Dun Rubha na Mòine le im a MLWS MLWS Rubha Breac Shingle Quarry(disused) Dru Chla chac ld ers & Sh MLWS (remains of ) Rock Shi ng MLWS Keeper's Cotta ge Bou Shingle and Creag EER,Co Const & Loch nan Druimnean Bould ers UA Bdy 6.4m
Rock Rock Rock Spreads Track 57.3m
Dra MLWS Cullaloe Cottage Shingle in Dun Loch a ' Phe arsain MLWS MLWS MH& DùnCrutagai n (remains of ) Top Ardenstur Fearnach Bay Jet ty Quarr y MLWS Water (um) Path Collects
(dis ) Rock Shingle Track Rock Boulders Scattered & Shingle Tra ck Rock MLWS 9.4m FBs MHWS Track Issues Sheepfold WS AnClèite adh Rock Seil Sou nd Rock DùnBeag Cotts ML Caiste al nan Con Shingle Shi ngle Track Jet ty Track Shingle and Bould ers MLWS FB Ford Issues Springs High Water Mean MS Cil le Eas a 'Mhuilin n-Iuaid h WS ire MH Shingle Track House Ardanst ur Sheepfold
Bould ers BarnKilchoan 52.4m Track (Wate rfa ll) d Mò d
Rock Port n a Morachd FarmhouseKilchoan Tra Rock Collects Collects Abhainnna ck FBs Ponds MLWS Kilchoan Track 10.1m Ford Fortif ied pri ngs r Springs r
Track Shingle and Bould ers Rock S r Loch Melfort Isla nd ate
Cuan ML WS MLWS te Sinks
Quarr y Cove WS Lnaag each ngle Shi ngs Collects 39.6m Issues
(dis ) FB Pond Rock Eile an F raoch MH Track Cre in High W Spri Water &
Co Dra Low Mean ngs Spring an Low Wa ers
ast Me an Track Rock pri Slip w ay Geàrr Sgeir Path (um) PathFB (um) ld Collects Barachule FB
al Bou Me Rock MLWS al Slo pe Kilchoan Cottage Shi ngle Collects 37.5m
Slo pe MLWS S te r MLWS MLWS Rock FB Kilchoan House ML WS Coast Ford Sinks Roc Shing
k k le w w Wa Shingle and Bould ers Ponds (um) Path Rock Enclo sure S h in g le & S CeannMòr cattered B Rocks Lo MH WS Rock Bould ers Track &RockShingle Creag a' ld ers Roc (sit eo f) Gle nbeg oulders Rocks Pond ShingleM e a n H ig h ShingleW a te r S p r Chagain n le Bou k 8.2m ings ng Mean Gla sEile an HouseBoat M e a n L o wB W o ua teld r e S r sp r& ing STrack hs in g le Shi Roc Lime Kil n Pier Shingle s
S Jet ty (dis used) Track ers Kil melford ng
ML WS ld Cille na Abhainn Shingle DhomhnuiCnoc ll Rock pri le 6.4m Collects
MHW MLWS Bou Rock Rock Rock Rock S Boulders Bàgh na Issues Kil melford a'MhuilEas inn
MLW Pon 94m MHWS Torsa ter Kilchoan Bay Roc Dala ch Du bh- Chla cha ic h Shi ng Loch na Cille Waterfall CottageGardenThe OldBarn k Rock ML WS Rock d Sgeir a' Bhodaic h Shingle Wa Bou ld ersBou ld Creag n a Fort Cuilfail Hotel Garbhein Criffel ers& & Pat( h um) Shingle Shingle Sheepfol d ers h-Uai dh Ruai dhe (rems of ) 7.9m &Sh ld ngle ers Rock and MLWS Low Bou Shi S h in g le & Sc a tte r e d Bo u ld e r s The Laurels AbhainnCuilna CilleAlltreidth Kin naird ingle Bould ers an Boulders Bould ers Bou Bould 6 Lodge ld ers & ersgl e TCB Quarr(dis )y Shingle Me Ford Ford ck Shi Roc k k C r e a g a n Fh ith ic h Track PO ng le Bould ers Rock LB Rock Rock Tra Rock Bould& Shin Roc RockTigh-na-Mara6.4m Terrace 1 Cuilfail TCBWarLB 19.2mThe Manse 68m Pond Bould ers & ScatteredRockShingle anCreagFhithich & 1816 A Meml Kilmelford Barrbae House Spring Shingle Tra ML k Boulders T h e O ld K irk ParishChurch Cnoc na 78m ck WS Rock Rock Bould ers MH Roc Shi ng Shingle 3.0m M e aAchnacille n H ig h W a te r Pond 5 Cuilfail Cottages Manse 77m DùnFadaidh WS le RubhaÀird anSt urra Ceàrdaic h MH ML WS Rock RockCarnaichSgeir MLWS Drain Dra Bould SgeirCeàrdaichna M e a nStoneShingle Allt CrioNaL och wW a te r S p r ing s 50m W in ers Rock Shingle Cull ip ool Sh Path (um) Mud Causeway MLWS Shingle SpringsCaol N'Mara Track Footbridge S k
ing le Ford Rock Coastal Ford Roc ShingleTel Cuilfail Wood Shelter CG
Quarr y Collects MHWS ExBalintore L ittleod17 T10 o rw o 105m (dis ) Sinks Shingle Rock Rock Tidal Pond Slope Track Rubha Cai lleach a 'Bhin neinn Serendipity 20 19 16 1 Tel Ex
Rubha Bui dhe Mud Boulders MLWS Shingle Tank ers Bould Eile an 21 THE18 GLEBE2
WS Boulders&Shingle Ford Rock Colta ir Loch Melfort ViewSea ESS GLEBE1314 Weir Eas n aai C llic h
Rock Jet ty Issues Shingle Rock Seil Sound Boulders Boulders Coille Cille Playground22 12 THE
7 6 11
Rock Marsh Shingle4.3mLochend Dharaich 11a DunureCeo Na Mara 112m
10 B o u ld e r s & S h in g le Rock Pebble Beach View na Abhainn 9 Pat Rubh' an Ròinan Rubh' h &Boulders Shingle MHWS Marsh Cairn An Torr10.1m Rock &Boulders Shingle Caillich na Eas Torsa TorsaBeag Slo pe Boulders & Shingle Mean Low Kinloch
Drain Drain Cave Well B o u ld e r s & S h in g le al Dra in h Pat Shingle MeanSpringsWater High Shingle Track Track
Shingle and MLWS ford RockRock TidalPond Pat h Degnish W a te r S p r ing s Marsh 2.4m Hall 35
39
Bould ers Rock Rock ss Boulders Coast Rock Rock Tigh naRoi n MLWS 3.7m 49 40 Gla Reservoir(covered) Drain Issues &Shingle Boulders F Sta 44 43 ML MoP Rock Mud C o a s ta l S lo Drain Rock Rock NTL ings Rock Rock pe Spr Track B o u ld e r s & S h in g le (AWE WARD) le Luin g Shingle& BouldersShingle Torsa Rock ArdrowanTigh-Na-Bat a Pontoon M e a n H ig h W a te r MLWS Drain Mean Low Rock Springs LON SAY WARD Maol Eil ean Rock ur ng Shingle ter Hard MLWS Loch naMud &ShinCille gle Marsh Drain
WS MLW Shi ty SloCoa Track RockWater Wa Mud &Shin gle h ML Harbo Jet alst pe SpringsMean High TrackBoulders (um) SlopeCoastalPath Track Sgeir na Caill ich BoatRepairYard Path
Sgeir na s Collects Water Boulders RockTidalPond Path (um) Rock 4.0m
Beln ahu a h-Acairseid SpringsRockBouldersMLWSRock Mud &Shin gle Track Rock Mean Shingle Hig Rock TheGatehouse Camusdarach Mud & ShinNTLMLWS 136m Loch Mel f ort gle Sgeir Bhui dhe Collects Spring gle Drain Rock Rubha a nT ai ghe L ois gte Bould ers & 8.5m Collects
Rock Rock Shin & Mud Dra Shingle ShingleBoulders & Bould ers Clu an Sia r in Dra in Rock k A 816 5.8m Waterfall Cul lip ool Bardrishaig Boulders Shingle Roc Tullich MS Glenmore House MH WS Rock WS LB SPDO Achadh dà 4.9m Jet ty ML Rock PO Chaluim Collects Shingle Dun 15.8m Lodge Rock (AWE WARD) LB Sheep Wash MLWS (remains of ) Tank E a s a ' Ch o ir e ers& Boat House Shingle WS Track Glenmore Farm Tank
MLWS way Slip Gal lery House Track B o u ld eRock r s &Shingle SRock h in g le Sgeir a' Waterfall ML Bould Shi ngle Lig hthouse 4 1 GridCattle Ardinamir Bay Rock Rock Chlèiri ch FB ML WS Rock Fladda Drain Spring Rock Shingle Track Fla dda Slip way Track 20.7m Bàrr Beit he Spring Rock Rock Track Ford Gle nCottage MH & A 816
Rock FBDrain Track Shingle Rock ML WS Rock MLWS Rock Dig Mhò r MLWS Shingle Rock Tullich Cott age Rock GridCattle Dubh Leathad Drain Boulders ShingleRock Boulders& Shingle EasMhic gs FB Drain Boulders&Shingle Shingle Rock MS DrainAoidh Issues
Sou n d of L uin g MLWS Rgh Track Fort Track Shingle Àird Rubha Choin a' Rock Rock Shingle Sprin MHWS Issues Issues Drain DW Boulders MLWS MHWS Boulders&Shingle Degnish Poin t Shingle ter 9m Collects Beacon FTelephone Sta Shin &Mud gle Wa Well
MLWS Mud Exchange ArdinamirShingle Mud &
Rock MLW Track Ardinamir Shingle Bay ShingleMHWS Bould ers &
Cairn Rock Rock Rubh'an AirdFhada w Shi ngle Track ML Shingle FB FB FB GridCattle Shingle Rock Rock Tra
WS ck RockMHWS (AWE WARD) Rock Dam in Issues FB FB Shingle Loc h Me lf o rt Shingle Lo Mean Dra FB Boulders& ShingleArdbeithe & Eas a Cat tle Grid Track Rock Boulders FB Rock ' C ho MLW Lui ng Drain Drain BàghLachlainn Rock ML WS Rock FB Rock Rock 9m ire Dubh Sgei r MLW Rock Tigh-an-Rudha Kames Ba y Mea ll M òr Rock ShingleMHWS LodgeKames Waterfall
MHWS ds C o a s ta l S lop e
MLWS Dam Pon Rock Rock Eas M hi c A oi dh
Rock Gla sEile an MLW ile an FB Rock Boulders &
Orms a te er ShingleCraigaol ML WS an sg Luin g Loch Melfort &
MH WS ers Bould Eile Loi Lobst E Fraoch Shingle BouldersCraiglea &
Mud Drain Shingle Boulders & Shingle Pie r ld ers ngle Dia rSgeir Laroch Rock Bou Shi MLW Rock hail Sgeir nan Sai dhean Rock and Dam FB Rock Creag-Na-Linne Bould ers & Dra
Bould ers Rock Bould ers MLW in Furac Track Rock Shi ngle 10m ISLAY NO RTH ,J URA AND CO LON SAY WARD Rock Tulloch Beag Loch a' Chlachain MLWS FB Bin ne FB Tobair-na-suil Collects Rock
Shi Creag Aoil 16 MHWS Roc ng le Drain ngs A 8 k MLWS Rock Spring Drain Spri HighWater Springs Rock
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k Well MLWS ML Ford Dail TowersCorrie Mull ach Dubh Drain Collects MLWS Rock Eile an Arsa Shingle Sound of Luing MHWS
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rin gs Shingle The Lair Dra Issues Cairn in Sp rin The Den Lunga Heig hts Drain gs Àir d Luin g MH WS MhicPort Isaaic Lunga Issues ingle Gardens TankSt Fillan's Well 49.4m Rock & Sh & Rock Shore Cotta ge Pond Issues Shingle & Sand
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g-u illt Sh ing le Roc Well Weir Bàn Rubha k Waterfall Springs Ann Gle ann MLWS Issues Tom Dubh r ld ers Bou Bàgha B ' hàn-Rubha 65m Rock k BhreacCreag Loch a' Mhadaid h w Wate Cave Shi ngle Roc Drain Druim a Sh Drain n Searra Waterfall an Lo ing ich Me Rock le Drain Drain Tom Dubh Track
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Scarb a Path (rems of) uld MLWS Roc k Rock Issues GridCattle 3.7m Tra Bo ngs Spri Water Gemmell Ardlarach MS Weir Dùn anDubh -Ch a lla ck allt ML Low Mean WS The Barn Issues BridgeBarbreck
g- Sand Rock Dubh Allt Drain
WS Drain Drain River WS An Ea An Rock San MH Ca ML Port Caol Drain 61.9m d ola Water Springs Issues Drain Barbreck
Aoineadh n a Rock s High Mean Issues Collects 53.3m Spring Spring
Rock Sheepfol d h-Uamh a Rock an Shingle 8.5m Waterfall (Cave) MLWS Collects Drain
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Scarb a MLWS Rocks Drain Track lay-by Drain
BàghAoi neadh Rock Culbhaic MLWS Loch na h-Ardla raich Issues Application Site Shingle Track na h-Uamh a Drain Shingle Rocks Lime(disused) Kiln B 8002 Sinks Drain
MLWS Issues Mount Hawk 45.1m Track MLWS NTL Drain 3.0m Sh ing le MLWS Tank MLWS Roc WaterSprings Tanks Lerigoligan Well 6.1m Rock k MLWS Low Mean Shingle Lairfad GridCattle Acarsaid Boulders & Shingle Shingle MeanSprings HighNTL Creachann Water Drain LodgeEast Blànan r Sit h Rocks Tigh AnLochan Bridge End Craigard Grianan Rock Sand &Shingle MLWS CottageRowantree DachaidhShealbach Tigh naDarroch Pond Track Rock Sgeir nam Fig headair CottageHillside Rowancraig Tigh naCamusTigh-nan-Eilean Causeway Sand & Shingle Shingle
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Drain 49.4m Mast Fort Pond SandShi ngle & Shingle Shi ngle 2m Bould ers MS Lochan TighChoinnich Innisaig Cottage Shingle 40.8m Well 1:250,000 Cal adh Reid h Tra ck
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Tigh ClaNa chair Cladach Cottage B 8002 A 8 rtein Mhài Pond Pond Pond FB 16 WS ers (T) ML BàghDai l ld Issues SorobaCottage Toberanna S tro n e fie ld The Anchorage 115m hi c MHWS nan Ceann Bou Soroba 6.4m Shingle Sheep Wash
Scarba Rock Shi Drains Drains Spring House Quercus Highfield Simla Scarbhse Hou 4The1 Eile an In shaig Bould ers Quarr y M Àth t ng Mean Low Water Spri ngs Low Water Mean Bould ers All ers Dun Ailn e Culrain Fraoch M aFinnart p le H o u ChamberedClachant-se CairnSagairt Tigh Duin AnchorageTCBSlipway Jet ty (dis used) Sal achary ck le Pond Cruac h Tra Tra ck ld InnessTigh-An- Achnashie Cottage Drain Beinn-an-Duin CentreArdfernYacht Jetty (CRAIGNISH-GLENARAY WA RD)
Ponds Bou Sand eir eig Creel Collaig Dunskeig Tigh nanGillean BluebellCottage Little Yellow House Boulders MLWS WS Scarb a p Track Drain Ardlamont OwlBarnhillBarn 13.1m TrackArdupp Ach-an-Duin 3.0m Jetty ML a S a Ponds Drain Albione Lodg Boulders Shingle 138m h n h Àth Mhic
449m Rock Cairns Crannog Keppoch House Dunad Aarhus Eiridh-Na-GreineThe SmithyOld Shingle Boulders Mhàirt(Ford) ein
Ponds ille ac TrackFB Drain The Sula PrimaryCraignishAndorlinn 4 S Bould ers Masts chool1 Ponds Ca Drain Collects Sinks Homestead RigsBarley Joorzraw PO Springs Roc k Cairn FB Pond Port a n t-Sruthain Collects Pond PondDrain Campion MalinBuie FishThe Shell Boat naRadharc Mara MeanWater Low (sit eo f) Track
a hPat Collects Track Corranbeg Issues Millburn Yard House
Water WorksWater TimbacardiaTigh Na LowerSoroba Willow HouseCottagesArdfern 4 F Sta Drain Shingle Cre ag n am LB1 Ardfe rn ngs Ford ArdfernHouse SubEl Sta TCB 7.6m Be-hive Bou ld ers SpriBould ers Pit ter k Tigh aVuilli n Mallard Wa Fi (dis ) the Pond Roc Drain Millhouse 3.0m Teal Widgeon Springs Water ac h Uamh Ghil lean Dail n an Ceann Loch Fada TrackWar Galley of LorneIn n High Mean Loch Craignish l (Cave) Meml Eider Shingle oi and d Drain Water MeanLow ha S Eilean na h-Eaglaise M
Shingle and Boulders
Shingle MLWS
Rock Rock Rock Shingle Drain S MH & Dùn Crutagai n MLW Water Rock Shingle MLWS
Rock Rock Seil Sound Caisteal nan Con Shingle MLWS Shingle Port na Morachd 713600 713600
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Ponds e Boulders
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ML Dra Drain in S W H M k Trac
Shingle Tank Ford 712800 712800
pe
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rain Rock Drain
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Rock
M M H & LWS Shingle Rock le Rock ing Sh Rock Rock Rock Shingle oulders Degnish Point Shingle Shingle
ock Rock Shingle Rock 712000 712000
hl ainn Reproduced from the Ordnance Survey map with the permission of the Controller of Her Majesty's Stationery Office (C) Crown Copyright 2009. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or Civil Proceedings. OS License No.100023368, 2009.
176200 176800 177400 178000 178600 Location Plan relative to Application Ref: 11/01066/MFF ° Date: 24.08.2011 Scale: 1:15,000 Page 112
This page is intentionally left blank Page 113 Ref: ABH1/2009
ARGYLL AND BUTE COUNCIL
PROCEDURE NOTE FOR USE AT
(1) Statutory Pre Determination Hearing (2) Pan 41 Hearing (3) Council Interest Application (4) Discretionary Hearing X
HELD BY THE PLANNING, PROTECTIVE SERVICES & LICENSING COMMITTEE
1. The Director of Customer Services will notify the applicant, all representees and objectors of the Council’s decision to hold a Hearing and to indicate the date on which the hearing will take place. The hearing will proceed on that day, unless the Council otherwise decides, whether or not some or all of the parties are represented or not. Statutory consultees (including Community Councils) will be invited to attend the meeting to provide an oral presentation on their written submissions to the Committee, if they so wish.
2. The Director of Customer Services will give a minimum of 7 days notice of the date, time and venue for the proposed Hearing to all parties.
3 The hearing will proceed in the following order and as follows.
4 The Chair will introduce the Members of the Panel, ascertain the parties present who wish to speak and outline the procedure which will be followed.
5. The Director of Development and Infrastructure’s representative will present their report and recommendations to the Committee on how the matter should be disposed of.
6. The applicant will be given an opportunity to present their case for approval of the proposal and may include in their submission any relevant points made by representees supporting the application or in relation to points contained in the written representations of objectors.
7. The consultees, supporters and objectors in that order (see notes 1 and 2), will be given the opportunity to state their case to the Council.
8. All parties to the proceedings will be given a period of time to state their case (see note 3). In exceptional circumstances and on good case shown the Panel may extend the time for a presentation by any of the parties at their sole discretion.
Page 114 Ref: ABH1/2009
9. Members of the Panel only will have the opportunity to put questions to the Director of Development and Infrastructure’s representative, the applicant, the consultees, the supporters and the objectors in that order.
10. At the conclusion of the question session the Director of Development and Infrastructure’s representative, the applicant, any consultees present, the supporters and the objectors (in that order) will each be given an opportunity to comment on any particular information given by any other party after they had made their original submission and sum up their case.
11. The Chair will ascertain from the parties present that they have had a reasonable opportunity to state their case.
12. The Panel will then debate the merits of the application and will reach a decision on it. No new information can be introduced at this stage.
13. The Chair or the Committee Services Officer on his/her behalf will announce the decision.
14. A summary of the proceedings will be recorded by the Committee Services Officer.
15. If at any stage it appears to the Chair that any of the parties is speaking for an excessive length of time he will be entitled to invite them to conclude their presentation forthwith.
NOTE
(1) Objectors who intend to be present and speak at a hearing are encouraged to appoint one or a small number of spokespersons to present their views to concentrate on the matters of main concern to them and to avoid repetition. To assist this process the Council will provide a full list of the names and addresses of all objectors.
(2) Supporters who intend to be present and speak at a hearing are encouraged to appoint one or a small number of spokespersons to present their views to concentrate on the matters of main concern to them and to avoid repetition. To assist this process the Council will provide a full list of the names and addresses of all supporters.
(3) Councillors (other than those on the Panel) who have made written representations and who wish to speak at the hearing will do so under category (1) or (2) above according to their representations but will be heard by the Panel individually.
(4) Recognising the level of representation the following time periods have been allocated to the parties involved in the Hearing.
Page 115 Ref: ABH1/2009
The Director of Development Services’ representative – not more than half an hour The Applicant - not more than half an hour. The Consultees - not more than half an hour. The Supporters - not more than half an hour. The Objectors - not more than half an hour.
(4) The purpose of the meeting is to ensure that all relevant information is before the Panel and this is best achieved when people with similar views co-operate in making their submissions.
(5) Everyone properly qualified as a representee recorded on the application report who wishes to be given an opportunity to speak will be given such opportunity.
(6) The Council has developed guidance for Councillors on the need to compose a competent motion if they consider that they do not support the recommendation from the Director of Development and Infrastructure which is attached hereto.
I:data/typing/planning/procedure note Page 116 Ref: ABH1/2009
COMPETENT MOTIONS
• Why is there a need for a competent motion?
o Need to avoid challenge by “third party” to local authority decision which may result in award of expenses and/or decision being overturned.
o Challenges may arise from: judicial review, planning appeal, ombudsman (maladministration) referral. All appeal/review processes have rights to award expenses against unreasonable/unlawful behaviour.
• Member/Officer protocol for agreeing competent motion:
o The process that should be followed should Members be minded to go against an officer’s recommendation is set out below.
• The key elements involved in formulating a competent motion:
o It is preferable to have discussed the component parts of a competent motion with the relevant Member in advance of the Committee (role of professional officers). This does not mean that a Member has prejudged the matter but rather will reflect discussions on whether opinions contrary to that of professional officers have a sound basis as material planning considerations.
o A motion should relate to material considerations only.
o A motion must address the issue as to whether proposals are considered consistent with Adopted Policy of justified as a departure to the Development Plan. Departure must be determined as being major or minor.
o If a motion for approval is on the basis of being consistent with policy reasoned justification for considering why it is consistent with policy contrary to the Head of Planning’s recommendation must be clearly stated and minuted.
o If a motion for approval is on the basis of a departure reasoned justification for that departure must be clearly stated and minuted. Consideration should be given to holding a PAN 41 Hearing (determined by policy grounds for objection, how up to date development plan policies are, volume and strength of representation/contention)
o A motion should also address planning conditions and the need for a Section 75 Agreement.
o Advice from the Scottish Government on what are material planning considerations is attached herewith. However, interested parties should always seek their own advice on matters relating to legal or planning considerations as the Council cannot be held liable for any error or omission in the said guidance. Page 117 Ref: ABH1/2009
DEFINING A MATERIAL CONSIDERATION
1. Legislation requires decisions on planning applications to be made in accordance with the development plan (and, in the case of national developments, any statement in the National Planning Framework made under section 3A(5) of the 1997 Act) unless material considerations indicate otherwise. The House of Lord’s judgement on City of Edinburgh Council v the Secretary of State for Scotland (1998) provided the following interpretation. If a proposal accords with the development plan and there are no material considerations indicating that it should be refused, permission should be granted. If the proposal does not accord with the development plan, it should be refused unless there are material considerations indicating that it should be granted.
2. The House of Lord’s judgement also set out the following approach to deciding an application:
- Identify any provisions of the development plan which are relevant to the decision, - Interpret them carefully, looking at the aims and objectives of the plan as well as detailed wording of policies, - Consider whether or not the proposal accords with the development plan. - Identify and consider relevant material considerations for and against the proposal, and - Assess whether these considerations warrant a departure from the development plan.
3. There are two main tests in deciding whether a consideration is material and relevant:
- It should serve or be related to the purpose of planning. It should therefore relate to the development and use of land, and - It should fairly and reasonably relate to the particular application.
4. It is for the decision maker to decide if a consideration is material and to assess both the weight to be attached to each material consideration and whether individually or together they are sufficient to outweigh the development plan. Where development plan policies are not directly relevant to the development proposal, material considerations will be of particular importance.
5. The range of considerations which might be considered material in planning terms is very wide and can only be determined in the context of each case. Examples of possible material considerations include:
- Scottish Government policy, and UK Government policy on reserved matters - The National Planning Framework - Scottish planning policy, advice and circulars - European policy - A proposed strategic development plan, a proposed local development plan, or proposed supplementary guidance Page 118 Ref: ABH1/2009
- Guidance adopted by a Strategic Development Plan Authority or a planning authority that is not supplementary guidance adopted under section 22(1) of the 1997 Act - A National Park Plan - The National Waste Management Plan - Community plans - The Environmental impact of the proposal - The design of the proposed development and its relationship to its surroundings - Access, provision of infrastructure and planning history of the site - Views of statutory and other consultees - Legitimate public concern or support expressed on relevant planning matters
6. The planning system operates in the long term public interest. It does not exist to protect the interests of one person or business against the activities of another. In distinguishing between public and private interest, the basic question is whether the proposal would unacceptably affect the amenity and existing use of land and buildings which ought to be protected in the public interest, not whether owners or occupiers of neighbouring or other existing properties would experience financial or other loss from a particular development.