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Formation of 14 Cage Fish Farm Including Foodstore/Service/Pontoon Site Address : Eilean Grianain, Kilbrannon South, North of Carradale, Campbeltown

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Formation of 14 Cage Fish Farm Including Foodstore/Service/Pontoon Site Address : Eilean Grianain, Kilbrannon South, North of Carradale, Campbeltown 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 : 09/00905/MFF Planning Hierarchy : Local Development Applicant : Ocean Shells Ltd. Proposal : Formation of 14 cage fish farm including foodstore/service/pontoon Site Address : Eilean Grianain, Kilbrannon South, North of Carradale, Campbeltown DECISION ROUTE Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • Formation of 14 cage Marine Salmon Fish Farm; • Installation of food storage and service barge. (ii) Other specified operations • Servicing from Carradale Harbour (B) RECOMMENDATION: Recommend that permission be granted subject to: i) the conditions and reasons attached; ii) a discretion ary local hearing being held in advance of the determination of the application in view of the number of representations received. (C) CONSULTATIONS: East Kintyre Community Council (07.09.09) - No objections, support is expressed for the proposal in view of the likelihood of employment creation in East Kintyre and perceived benefits from the use of Carradale Harbour to service the development. Campbeltown Community Council (22.09.09) – Express support for the proposal on the grounds that the benefits to the community will outweigh objections on the grounds of adverse visual impact. It is noted that there appear to be few objections from Carradale residents and the proposal will help revive the fortunes of this fishing community in terms of economic development and employment creation. Northern Lighthouse Board (17.07.09) – Comments in respect of the requirement for navigational markings. Transport Scotland (20.07.09) – No comments. Scottish Environment Protection Agency (SEPA) – (22.07.09) No objections to the development from a planning and EIA perspective although it is noted that a CAR licence will be required. Confirm that the site is outside any Scottish Executive Environment and Rural Affairs Department (SEERAD) category area, and that no Area Management Agreement (AMA) is in place covering the area. Argyll District Salmon Fishery Board (ADSFB) – (03.08.09) Object to the proposal – In summary, advise that the proposed development gives rise to concern with regard to wild fish interests in the following respects: (i) Scale: That the proposal relates to a very large tonnage in a previously unfarmed stretch of water and as such has significant potential to impact on fragile wild salmon and sea trout populations. In this respect it is suggested that the proposed scale of the development should be reduced significantly until such time as it can be substantiated that the location and management of the site does not impact on wild salmon and sea trout. In order to support this process it is suggested that the developer commissions a full survey of fish populations in the Carradale, Claonaig, Skipness, Iorsa and Machrie catchments prior to the development with further monitoring of sea-lice populations and wild fish through a minimum of two production cycles (4 years) to assess whether further development at this site is appropriate. It is also acknowledged that whilst halving the proposed tonnage would not eliminate the potential impact of the site upon wild fish, it would be reasonable to deduct that such a reduction would proportionately reduce the number of sea lice produced at the site. (ii) Cumulative Impact: Concern was originally expressed in respect of the potential impact of the proposed development cumulatively with that of two proposed sites for cod farms further to the north on the assumption that consent would later be sought for the use of one or both of these sites for salmon in order to balance production at Eilean Grianain thus preventing synchronous production in the Kilbrannon Sound. The applicant has subsequently clarified that the currently proposed development is economically viable on its own with production to be balanced by integration with Lakeland’s other sites in Mid Argyll and Shetland and the grounds of objection have been removed in this respect with the caveat that, in the event that the current proposal were to be approved, that any further salmon farm development within the Kilbrannon Sound would require to take into account cumulative impacts. (iii) Impacts on Wild Salmon and Sea Trout: Objection is raised to the findings of the ES which state “that the effect of Eilean Grainain on wild fish to negligible/low” – this objection being raised on the grounds that this statement is based on comments based on observation rather than any substantiated scientific evidence. Available data on juvenile fish populations in the rivers close to the proposed development indicates that this area is of significance to maintain wild salmon and sea trout populations. For this reason there should be an assumption of some interaction of farm and wild fish particularly in relation to sea lice transfer and potential for escapee fish to enter local rivers; it should be assumed that the farm has potential to impact and a precautionary approach taken. In the event that the application were to be granted it is suggested that any such consent should include an agreement by the applicant to provide increased ‘in river’ monitoring on wild fish and post smolts to ascertain any effects the farm may have together with judicious lice level monitoring at the site by the applicant/Fish Health Inspectorate. Following further discussion with the applicant, the effort of Marine Fish Farm operators and the applicable Code of Practice to control sea lice levels is acknowledged, in particular it is noted that Lakeland appear to have a good lice control record elsewhere; however, this in itself is not sufficient basis to remove objections in respect of the above. (iv) Fisheries: It is noted that the proposal could potentially impact upon coastal netting rights in the vicinity. Whilst it is the Board’s policy to discourage coastal netting it is advised that affected parties have been advised and invited to make representation on the current proposal directly to the planning authority. (v) Connectivity Between Sites: Concern was originally raised on the assumption that the current application is part of a larger plan to create two, possibly three salmon farms on the East Kintyre Coast, the other sites being at Port Fada and Rubha Riabhach. In view of this concern it was requested that the applicant provide information on tidal overlaps relating to the dispersal of Infectious Salmon Anaemia (ISA) – this information has not been provided in the ES; clarification was also sought as to whether the development, in combination with the other sites would form part of an existing Area Management Agreement (AMA). Following further discussion with the applicant this concern has largely been removed with regard to the determination of the current proposal in respect of the potential for further development (see Cumulative Impacts above) and with confirmation that, as Eilean Grianain is outwith any existing management production area and as such has no tidal overlap with Arran or Loch Fyne sites owing to the large separation distances, the developer is committed in principle to participating in a new AMA covering this site. (vi) Sea Lice: Concern was originally raised that the submitted ES did not satisfactorily take into account the dispersal of sea lice from the site and the potential impact upon wild fish. Following further discussion with the applicant it was confirmed and acknowledged that at the present time there is no verified sea lice larvae dispersal model available for the Kilbrannon Sound. (vii) Sea Lice Treatments: Concern was originally raised over the longer-term effectiveness of current sea lice medicines. Following further discussion with the applicant, in which Lakeland have explained that it seeks to control sea lice in line with industry best practice and that the quantity of therapeutic sea lice treatment is regulated by SEPA, it is acknowledged that Lakeland would appear to have obtained licence for a sufficient stock of medicines to treat the large bio-mass proposed. (viii) Predator Control: Concern was originally raised in respect of the applicant’s intention not to install Acoustic Deterrent Devices (ADDs) at the site in view of the generally high number of seals present within the Kilbrannon Sound. Following further discussions, the applicant has advised that the decision not to install ADDs was arrived at in view of SNH’s concerns that the use of such devices may adversely impact upon Cetaceans; however, more sophisticated ADDs are currently being trialled by the applicant in other locations with test results indicating that these devices are more effective than previous systems with more localised results – it is the intention of the applicant to liaise with SNH with a view to utilising these more advanced devices at this site if possible. The Board welcomes the applicant’s decision to liaise with SNH with a view to utilising these more advanced devices at this site. Marine Scotland/Fisheries Research Services (04.08.09) & (19.08.09) – No objections having established the suitability of the equipment for this location and having been satisfied that the applicant would put in place appropriate contingencies for removal and disposal of
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