DEVELOPMENT SERVICES Ward 8: Isle of Bute PLANNING APPLICATION REPORT Date of Validity 1st February 2006 Bute and Cowal Area Committee Date 6th November 2007 18th October 2007 Reference Number: 06/00270/MFF Applicants Name: Mr Donald MacPhee Application Type: Marine Fish Farm Application Description: Proposed Salmon Fish Farm Location: Site 500 Metres To The North Of, Inchmarnock Fish Farm, Rothesay. (A ) THE APPLICATION This application relates to the formation of a fish farm covering a total area of 500 square metres and comprising 16 circular plastic cages measuring 90 metres in circumference and 1 feeding barge. (B ) RECOMMENDATION It is recommended that an objection be raised on the grounds listed below. (C ) DETERMINING ISSUES AND MATERIAL CONSIDERATIONS The mains issues in the determination of this application centre around landscape and visual impact, increased risk of disease spread and adverse impact on tourism as a result of the proposed fish farm. Given the location of the application site off the west coast of Bute and the scale of the proposed development it is considered that a fish farm at this location would present an alien form of development that would be at odds to the surrounding landscape/seascape character of the area. For this reason the proposal is contrary to both the adopted and emerging local plans in addition to the approved structure plan and national planning guidance. These concerns are also supported by Scottish Natural Heritage who has raised an objection to this application given its likely adverse landscape and visual impact. The Scottish Government’s Marine Directorate, formerly known as SEERAD, have advised that the position of this proposed site would bridge existing management areas – 19A (Loch Fyne) and 19B (Kyles of Bute). This would create a huge management area and would risk the spread of disease in this area between fish farms. It is important from a fish health perspective to maintain firebreaks between management areas in order to reduce the risk of disease spread. In addition the Argyll District Fisheries Trust has raised concerns regarding the increased lice levels within the north east tidal drift that would have a detrimental effect on the only migratory fishery in the area. It is also considered that the scenic value of the island and the recreational opportunities available will be undermined as a result of this development which in turn will have a negative effect on tourism. (D) REQUIREMENT FOR A HEARING While this application is contrary to Development Plan policy and a significant number of objection letters have been received against this application, the Planning Authority is only a consultee in this process and, as such, it is not recommended that a discretionary hearing need be held before this application is progressed. Angus J Gilmour Head of Planning Services Case Officer: J. Irving 01369-70-8621 Area Team Leader D. Eaglesham 01369-70-8608 "In reaching my assessment on this application, I have had regard to the documents identified in brackets above which are available for public inspection in terms of the Local Government (Access to Information) Act 1985". E:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002960\AI00037032\00270WRPROPOSEDFISHFARMINCHMARNOCKISLEOFBUTE0.DOC 1 REASONS FOR OBJECTION RELATIVE TO APPLICATION 06/00270/MFF 1. Given the location of the application site off the west coast of Bute and the scale of the proposed development; 12 circular cages, measuring 90 metres in circumference resulting in a development covering a total area of more than 12,000 square metres in size. This will result in a man made intrusion located within an unspoilt landscape/seascape that has been defined and protected as such through both the adopted and emerging local plans. This in turn would diminish the high scenic value of this part of the island. Importantly, the development is likely to have serious adverse impacts on the integrity of the presently undeveloped landscape/seascape character of the Sound of Bute. The development is also likely to have serious adverse impacts on the high scenic quality open sea views from the A844 road and the immediate west coast of Bute adjacent to Inchmarnock This proposal is therefore considered to be contrary to policy POL RUR 1 ‘Landscape Quality’ of the adopted Bute Local Plan 1990, policies LP ENV 1 ‘Development Impact on General Environment’ , LP ENV 10 ‘Development Impact on Areas of Panoramic Quality’ and LP AQUA 1 ‘Shell Fish and Fin Fish Farming’ of the emerging Argyll and Bute Modified Finalised Draft Local Plan 2006 and policy PROP CP 1 ‘Aquaculture & Development Control’ of the adopted Argyll and Bute Structure Plan 2002. In addition to the principles set out in the Scottish Executives Scottish Planning Policy 22 ‘Planning For Fish Farming’ (2002). 2. The maintenance of Management Areas is one of the principal means of minimising the risk of disease spread between fish farms and the impact of Infectious Salmon Anaemia (ISA) and Viral Haemorrhagic Septicaemia (VHS). The position of this proposed site would bridge 2 management areas – 19A (Loch Fyne) and 19B (Kyles of Bute). This would create a huge management area and would risk the spread of disease in this area. It is important from a fish health perspective to maintain firebreaks between management areas in order to reduce the risk of disease spread. In addition, the only wild migratory fishery operates within the north east tidal drift from the proposed fish farm is Drummachloy Burn. This could give rise to increased lice levels at crucial times of salmon smolts entering the marine environment. Sea Trout’s are also particularly prone to sea lice infestation, in the main feeding close to the shore where unattached lice larvae also congregate. Any increase in sea lice is likely to cause sea trout fishery to decline further. This proposal is therefore contrary to Policies LP ENV 12 ‘Water Quality and Environment’ and LP AQUA 1 ‘Shell Fish & Fin Fish Farming’ of The Argyll and Bute Modified Finalised Draft Local Plan 2007. 3. The Isle of Bute is known for its scenic beauty and tourists visit the island for this reason. Should the scenic value of this island be eroded and undermined by inappropriate development, such as this fish farm, it may have an adverse effect for tourism. It also follows that, should recreational opportunities such as sailing, canoeing and walking be undermined as a result of this development, this will also have an adverse effect on tourism. For this reason, this application is considered contrary to the principles of Scottish Planning Policy 22 (2007) ‘Planning for Fish Farming’ . E:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002960\AI00037032\00270WRPROPOSEDFISHFARMINCHMARNOCKISLEOFBUTE0.DOC 2 APPENDIX 1 RELATIVE TO 06/00270/MFF A. OTHER MATERIAL CONSIDERATIONS (i) Site History None (ii) Consultations Clyde Fisheries Association ( letter dated 27 th February 2006): Objection. • There are a reasonable number of fishing tows falling either directly within the application site or are so adjacent to it as to render them unusable. The reason for their being rendered unusable is that no one will risk dragging gear close to the fish farm and incur the risk of gear being destroyed. • Perhaps greater weight should be placed on the navigation as it is quite unacceptable that such an impediment to navigation in such busy waters be permitted. I cannot overemphasise the strength of feeling on the matter. Scottish Executive Environment & Rural Affairs Department (letter dated 28 th March 2006, 29 th January 2007and 25 th September 2007): Objection. • The position of this proposed site would bridge 2 management areas – 19A (Loch Fyne) and 19B (Kyles of Bute). This would create a huge management area and would risk the spread of disease in this area. It is important from a fish health perspective to maintain firebreaks between management areas in order to reduce the risk of disease spread. The maintenance of Management Areas is one of the principal means of minimising the impact of Infectious Salmon Anaemia (ISA) and Viral Haemorrhagic Septicaemia (VHS). We therefore strongly recommend that this development should not go ahead. Scottish Natural Heritage (letters dated 22 nd March 2006 & 8 th February 2007): Objection: • The development is likely to have serious adverse impacts on the integrity of the presently undeveloped landscape/seascape character of the Sound of Bute. • The development is likely to have serious adverse impacts on high scenic quality open sea views from Ettrick Bay and A844. • The development is likely to have serious adverse impacts on the setting of St Ninians Chapel. Northern Lighthouse Board (letter dated 1 st February 2006): No objection. • Site to be marked with 2 lit yellow poles, one to be positioned at the most north-easterly extremity of the site the other at the north-westerly extremity. • Feed barge on site is required to exhibit an all round fixed white light should be exhibited from a point at least 1 metre above any obstruction. • Once the site has been established the applicant should inform the Northern Lighthouse Board and UK Hydrographical Office. Argyll District Salmon Fishery Board (letter dated 16 th March 2007): Objection. • The Environmental Impact Assessment gives no basis for suggesting any research has been undertaken to determine whether or not there us a tidal overlap with either the management areas of the Kyles of Bute or Loch Fyne. We request that before consent is considered this should be undertaken by Fishery Research Services. • We have grave concerns that, as the EIA points out, in general the water currents around Inchmarnock site run SSW to NNE meaning not only will detritus dispersal follow this general direction but also it will be the general direction for lice and disease dispersal. Both the Kyles of Bute and Loch Fyne lie N/NE sector from the proposed site.