DEVELOPMENT SERVICES Ward 8: PLANNING APPLICATION REPORT Date of Validity 1st February 2006 Bute and 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, Fish Farm, .

(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 (). 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".

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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 . 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 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’ .

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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 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. • The question should be asked as to how the farm will employ six people, especially when it is proposed to use automatic feeders. At times of farming out, more manpower may be needed; however this will take place over less than one third of the operational cycle, probably using seasonal labour. Royal Society for the Protection Birds (letter dated 1 st February 2006): No objection. • I am not aware of any important sites or concentrations of birds that would be adversely affected by these proposals. Scottish Environmental Protection Agency (letter dated 9 th March 2006): No objection. • No conflicts with Marine Natural Heritage designations are anticipated. The benthic survey illustrates that the site lies over uniform sandy sediment; no species of natural heritage importance were listed.

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Royal Yachting Association (letter dated 24 th February 2006): No objection. Scottish Rural Property & Business Association : No response. Highlands & Islands Enterprise : No response Bute Community Council (letter dated 23 rd March 2006): Objection to this application based on adverse impact upon tourism, the environment, and amenity impact.

(iii) Publicity and Representations

The proposal was advertised by the Crown Estate. 139 letters of representation have been received against this proposal. Details of representations received form an attachment to this document in Appendix 2. In addition, a petition containing 135 signatures was received on 22 nd March 2006 objecting to the proposed fish farm given its adverse landscape impact and pollution to the surrounding waters including Ettrick Bay. The points raised have been categorised and summarised below: Procedure/Notification : • The correct procedure for notifying the public has not been adhered to. The advertisement was not published in the local paper, rather the Oban Times. Comment: The correct notification procedure was undertaken. Visual/Landscape Impact : • Adverse visual impact, detract from exceptional natural beauty of area. Eyesore with floats, boats, nets and plastic covers etc in the area. • Diminished outlook from St Ninians’s Bay and Point. • The proposed site lies within an area of outstanding natural beauty and should be protected. • The feeding barge will be permanently moored on site which stands a lot taller than the nets. The development will be clearly visible from the main road that passes the site (A844), the road is elevated and hence there will be an added visual impact for locals and tourists. • The proposal will from a man made intrusion upon an exceptional natural landscape. • Contrary to policy LP CST 2 ‘Costal Development on the unadopted Coast’ of the emerging local plan. Comment: The department has serious concerns regarding the landscape impact of this proposal for specific key vantage points. This will be examined in further detailed within the assessment below.

Amenity – Noise, Light Pollution : • Constant drone from the generators and the risk of fuel spillages to contend with. The peace and tranquillity that we currently enjoy will be damaged forever. • Light Pollution from high powered security lighting that can project across open water. • Odour nuisance. Comment: The development will be 1.6 km from the nearest dwellinghouse and silenced generators are used below the waterline of the feeding barge to mitigate against sound pollution.

Environmental Impact : • Adverse environmental impact, the faecal matter, toxins from anti fouling etc will pollute the surrounding area including Ettrick Bay. • Adverse effect on marine ecology and pollution of beaches and surrounding water. • The continuance of the seal colony at Scalpsie would be threatened given its proximity to the farm. • Extremely detrimental effect this type of intensive aquaculture has on water around the site and on the seabed below the cage. This leads to the deoxygenation of the seabed sediments which in turn wipes out the localised flora and fauna. • Tidal flows will deposit waste materials and toxins either directly onto the shore of St Ninians Bay or Inchmarnock Island or towards Ettrick Bay or Scalpsie Bay. • Use of chemicals to treat sea lice infestation would have a lethal effect on shellfish and fauna within the area of the farm and beyond dependent on the flow of the tides. • The use of copper based treatments on their cages is considered to be extremely toxic and this is astonishing given these cages hold fish for human consumption. • Diving birds could be affected by eating fish around the cages that could be infected by toxins. E:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002960\AI00037032\00270WRPROPOSEDFISHFARMINCHMARNOCKISLEOFBUTE0.DOC 4

• Existing wild salmon would be severely damaged. • This application, if granted, is likely to jeopardise the cleaning up of all beaches, particularly Ettrick Bay and progress on this has been hard and expensive. • The activity on the fish farm would almost certainly cause nesting Peregrine Falcon’s nesting near the site to vacate. • Adverse cumulative effect of this development in addition to other fish farms in surrounding waters. • Contrary to policies LP ENV 19 ‘Development Setting, Layout & Design’, LP BUS 2 ‘Business & Industry Proposals in CDC Zones’, LP AQUA 1 ‘Shell Fish & Fin Fish Farming’ and Appendix A of the emerging local plan.

Comment: A number of the concerns raised have been supported by SNH, SEERAD and the Argyll District Salmon Fishery Board. This will be examined in further detailed within the assessment below.

Effect on Tourism : • Tourists play a major part to the local economy and come to Bute to enjoy its natural beauty and this fish farm would jeopardised this. • To approve this fish farm would be to severely damage tourist attractions on the Isle of Bute and with it jobs and other related spin-off. • Damage to the water quality at Ettrick Bay on of Bute biggest tourist attractions. • Our Island economy is base on tourism and Ettrick Bay and St Ninian’s are tourist attractions. The fish farm would damage the island, seabed and spoil our spectacular scenery. • Inchmarnock is a popular destination for yachts, power and sail, to moot, the presence of a fish farm is likely to cause noise and pollute the water. Comment: The department has concerns the development may have an adverse impact on tourism as a result of a negative effect on recreation and an adverse landscape impact.

Commercial Impact : • The commercial case for increasing farmed salmon is a poor one. There is a plentiful supply of salmon to the point that it is being devalued already, without encouraging an even greater supply. • The proposal would jeopardise fishing and trawling in the area for high quality shellfish as the use of the proposed chemicals to treat Sea Lice Infestation would have the capability of acute and widespread damage to shellfish and fauna around the cage site. Comment: It is considered that there is insufficient information to justify an objection to this application on this basis.

(iii) Applicant’s supporting Information

The applicant has submitted a significant amount of information in support of the application, including an Environmental Impact Assessment, Landscape & Visual Impact Assessment, Analysis of Economic Impact, Analysis of Recreational Impact, Impact of proposed anti predation measures. This information is available for Members’ perusal; however, the following represents a summary of the main points:

• The Landscape & Visual Impact Assessment concludes that in local terms there will be no visual impact on the residents in East St Ninian’s Bay as the development is not be visible from there. There will be no impact to visitors to the beach at St Ninians Bay. The site will be visible from the A844 and from Straad but this impact will be low. The overall panoramic views and character of the landscape will not be significantly impacted. At a regional scale the visual impact will be low and will not adversely affect the Area of Panoramic Quality. In national terms the assessment concludes that the impact on the Scheduled Ancient Monument at St Ninians Point will be low in visual impact terms. The assessment concludes that the siting of the proposed farm follows Scottish Executive guidance which does not compromise the scale and quality of the landscape character.

• The Impact Assessment of proposed anti predation measures on marine turtles and Cetaceans concludes that marine turtles, Cetaceans and Basking Sharks are important groups that require and deserve protection in their natural habitats. Serious threats of entanglement from marine debris and activities to these groups exist. However, these serious threats are not presented by fish farming operations. OFD recognises the importance of these groups and recognises that small potential risk of entanglement in larger mesh anti predation netting. OFD has presented mitigation and rational analysis of the potential threats. OFD anti predation techniques are therefore unlikely to have any impact on these important groups of marine animals. OFD will act as marine observers reporting sightings of these groups to the appropriate organisations.

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• The Analysis of Recreational Impact concludes that the proposed development will have a negligible impact on recreational activity on the island. The analysis of the major recreational activities on the island indicates only a low visual impact to visitors to St Ninians Point with no impact on any other outdoor activities.

• The analysis of economic impact concludes that the Isle of Bute demonstrates a very narrow economic base, with a high dependency on the public sector and tourism. Wage levels are particularly low and productivity are low, which results in out-migration of economically active people and higher than average levels of deprivation. The aquaculture industry has demonstrated its suitability for contributing significantly to the diversification of the Highlands & Islands economy providing all year round employment and higher than average wages. At a local level, the proposed development will provide 6 direct jobs, with ancillary benefits downstream in transportation, maintenance and processing.

• The executive summary contained within the Environmental Impact Assessment concludes that the base-line surveys have demonstrated that the site is suitable for the development of a cage culture operation. The assessment acknowledges that there may be negative impacts on the local environment relating to deposition of particulate waste and other chemicals in the water but concludes that the risk associated with these are thought to be low because of the high water quality and high current speeds. The assessment further advises that there is likely to be significant impact on zooplankton in the vicinity of the cage site directly following treatment although this will diminish over time. OFD will instigate procedures and employ a regular environmental monitoring programme at their cage site to ensure that an acceptable level of environmental quality is maintained. In addition the assessment states that from available data the visual impact of the site will comply with the siting requirements specified by SNH and Argyll and Bute Council and will be of a low impact.

B. POLICY OVERVIEW

National Policy/Guidance

Scottish Planning Policy 22 – Planning for Fish Farms (April 2007) This SSP indicates that Planning Authorities should use the development plan process to support and encourage the continued growth of fish farming. Planning policies should not be used to restrict development where environmental and other impacts can be addressed satisfactorily. In all instances, Plans should, however, afford protection to areas designated for their national or international heritage value, and those areas where development would result in unacceptable significant impacts. The aim is to promote sustainable development in the most suitable locations. This SPP focuses on three general principles: • Recognising the needs of local communities and other users; • Safeguarding and enhancing the environment; • Promoting the sustainable development of fish farming.

Argyll and Bute Structure Plan 2002 Policy PROP CP 1 - Aquaculture & Development Control. The Argyll and Bute Local Plan shall include appropriate policies relating to shell-fish and fin-fish farming. The policies will accord with the principles and categorises contained in ‘Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters’, issued by Scottish Executive.

Bute Local Plan 1990

Policy POL RUR 1 – Landscape Quality The Council will seek to maintain and, where possible, enhance the landscape quality of Bute. The Council will resist prominent and sporadic development which would have an adverse impact on the landscape. All developments will therefore be required to be justified and assessed using the following criteria: • Environmental Impact; • Locational/Operational Need; • Economic Benefit; • Infrastructure and Servicing Implication; • Sterilisation of natural resource; • Alternative policies contained in the Local Plan.

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Argyll and Bute Modified Finalised Draft Local Plan 2006

Policy LP ENV 12 – Water Quality & Environment In all Development Control Zones proposals for development that could affect the water environment will be assessed with regard to their potential impact on: (A) Water quality and quantity; (B) Riparian habitats and wildlife; (C) Leisure and recreational facilities; (D) Economic Activity; (E) The resource potential protected by Policy LP ENV 1 and other relevant Structure and Local Plan policies. Developments that may have a significant detrimental impact on water environment will not normally be permitted unless it can be demonstrated that the impacts can be fully mitigated so as to ensure non- deterioration of waterbody status as required by the EU Water Framework Directive.

Policy LP AQUA 1 – Shell Fish & Fin Fish Farming There is a general support for shell fish and fin-fish farming subject to there being no significant adverse effect; directly, indirectly or cumulatively on: 1. Communities, settlements and their settings; 2. Landscape character, scenic quality, and visual amenity; 3. Loch Lomond and the Trossachs National Park; 4. National Scenic Areas & 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; 7. Area of Isolated Coast; 8. Site of historic or archaeological interest and their settings; 9. Recreational interests; 10. Areas of Search; 11. Existing Aquaculture sites; 12. Water Quality. In the case of marine fish farming, this support is further conditional on the proposals being consistent with other policies of the Structure and Local Plan, and the Scottish Executive Strategic Framework Guidelines. If a coastal framework plan is in place it should be considered as a significant material consideration in assessing any proposal, along with advice from all relevant statutory consultees. In the case of non-marine fish farming, this support is further conditional on the proposals being consistent with other policies of the Local and Structure Plan, and the Scottish Executive Strategic Framework Guidelines. In addition, a direct operational need tied to a specific location will need to be demonstrated where proposals are within sensitive countryside development control zones.

Policy LP ENV 9 – Development Impact on Areas of Panoramic Quality Development in, or adjacent to, and Area of Panoramic Quality will be resisted where its scale, location or design will have a significant adverse impact on the character of the landscape unless it is demonstrated that: (A) Any significant adverse effects on the quality for which the area has been designated are clearly outweighed by social and economic benefits of National or regional importance; (B) Where acceptable, development must also conform to Appendix A of the Local Plan. In all cases the highest standards, in terms of location, siting, landscaping, boundary treatment and materials, and detailing will be required within Areas of Panoramic Quality.

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C. ASSESSMENT (i) Site & Proposal Description This application is for a marine fish farm located within the Sound of Inchamarnock within waters to the north of Inchmarnock Island and to the west of the Isle of Bute. Inchmarnock is a small uninhabited island. However, there are a few isolated dwellinghouses and key vantage points on the Isle of Bute which will overlook the site. The proposal will involve the installation of 12 circular plastic cages that will each measure 90 metres in circumference. The cages will be sited in a formation of two by six pointing in a north direction. The cages will cover a total area of 0.03km within a total lease area of 0.2km. In addition to the cages it is proposed to have a feeding barge that will be moored at the fish farm. This will provide a storage facility for feed in addition to cleaning facilities and office accommodation. The applicant has advised that the site will be serviced from the existing Portavadie facility. In addition, the applicant has advised that the maximum production target will be 3000 tonnes with a maximum biomass of 1500 tonnes. The farm is for the production of Atlantic salmon. However the applicant has advised that over time this may diversify to cod farming. Feeding will be carried out automatically from the moored feeding barge while predator control will consist of high quality nets, acoustic deterrent devices will not be used. (ii) Landscape and Visual Impact Many representations have been received raising concerns that the proposed man-made fish farm will have a negative and adverse impact on the wider landscape and diminish the natural beauty of the area. The 12 circular cages, measuring 90 metres in circumference will result 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. Policy POL RUR 1 ‘Landscape Quality’ of the adopted Local Plan covers the entire Island and seeks to prevent development that would have an adverse impact on the landscape. Under the emerging local plan both the Isle of Bute and Inchmarnock are defined as ‘Areas of Panoramic Quality’ where policy LP ENV 10 applies, this policy seeks to resist development in or adjacent to such a designation where it would have a significant adverse impact on the character of the landscape. Policy LP AQUA 1 seeks to support fish farms subject to a number of caveats, including there being no adverse impact on the landscape character, scenic quality and visual amenity of the area. The applicant has submitted a detailed Landscape & Visual Impact Assessment for the proposed development. The conclusions of this assessment are detailed above but essentially state that there is little to no landscape impact on a local, regional and national basis. SNH have objected to this proposal on three mains grounds: 1) the development is likely to have serious adverse impacts on the integrity of the presently undeveloped landscape/seascape character of the Sound of Bute, 2) The development is likely to have serious adverse impact on the high scenic quality open sea views from Ettrick Bay and the A844, 3) The development is likely to have serious adverse impact on the settling of St Ninians Chapel. The department considers there to be a significant landscape impact on the high quality open sea views from the A844 and the immediate west coast of Bute adjacent to Inchmarnock as a result of the undeveloped seascape character being eroded by this proposal. However, it is considered that the views from Ettrick Bay are at such a distance that any impact will be reduced while the impact upon St Ninian’s Chapel will be limited. The landscape impact and visual amenity concerns that this proposal would create are of such significance that this proposal is contrary to the aforementioned development plan policies and warrant an objection to this application on this basis. (iii) Effect upon Fishing and Navigation The Clyde Fisherman’s Association has also expressed concerns regarding the location of the fish farm in such close proximity to fishing tows within the site and adjacent to it. This will prevent dredging in this area as no one will risk dragging gear close to the fish farm and incur the risk of the gear being destroyed. The Clyde Fishermen’s Association has raised concerns regarding the navigational impediment that the proposed fish farm will create. The Northern Lighthouse Board has raised no objection to this application subject to appropriate navigational bouys and markers being displayed on the fish farm. The Northern Lighthouse Board is responsible navigation safety under the Coast Protection Act 1949 and for this reason it is considered that their views outweigh those of The Clyde Fisherman’s Association.

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(iv) Effect Upon Recreation and Tourism Scottish Planning Policy 22 ‘Planning for Fish Farming’ states that both recreation and tourism are appropriate material considerations in considering applications for new or modification to existing fish farming developments. A large number of representations have been received raising concerns that proposed fish farm will have a negative effect on the Islands tourism industry which contributes a large part in the local economy. These concerns centre around three main issues; the adverse landscape impact of the fish farm in an area of natural beauty and spectacular scenery which people come to the island to enjoy, damage to the water quality at Ettrick Bay one of Bute biggest tourist attractions and the impact of the fish farm on Inchmarnock Island, a popular destination for yachts, power and sail, the presence of a fish farm is likely to cause noise and pollute the water. The applicant’s Analysis of Recreational Impact report concludes that the proposed fish farm will have a negligible impact on recreational activities on the island. SNH requested that such an analysis be undertaken in their original consultation response dated 22 nd March 2006 but has not raised any such concerns in the finalised response dated 8 th February 2007. As detailed above, the department considers there to be an adverse landscape impact as a result of this development. The Isle of Bute is known for its scenic beauty and tourist visit the island for this reason. Should the scenic value of this island be undermined by inappropriate development, such as this proposal it may have a negative knock-on 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 a knock-on, adverse effect for tourism. For this reason the department considers there to be a sufficient justification to object to this application on this basis. (v) Aspects of Pollution, Disease and Carrying Capacity SEERAD’s initial consultation response recommended that this proposal should not go head; the founding reason for this is that a fish farm north of Inchmanrock would bridge 2 existing management areas and increase the risk of disease spread in the area between existing farms and the proposed. The applicant and SEERAD have held discussions regarding this concern. However SEERAD have confirmed their original recommendation that this application should not go ahead. The department shares these views and given the concern raised this application is considered to be contrary to policies LP ENV 12 ‘Water Quality and Environment’ and LP AQUA 1 ‘Shell Fish & Fin Fish Farming’ of the finalised draft local plan. (vi) Nature Conservation Interests, Including Wild Fish Populations Scottish Natural Heritage has not raised any significant concerns in respect of the impact of the proposal upon nature conservation. Their objection relates to adverse visual/landscape impact only. The Argyll District Salmon Fisheries Board, the body which represents wild fishery interests has raised concerns that the only migratory fishery operating is Drummachloy Burn which is in the NE tidal drift from the proposed fish farm. This could give rise to increased lice levels at crucial times of salmon smolts entering the marine environment. Sea Trout’s are 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 relates to SEERAD’s concerns regarding disease spread, detailed above and for this reason this application is also considered to be contrary to policies LP ENV 12 ‘Water Quality and Environment’ and LP AQUA 1 ‘Shell Fish & Fin Fish Farming’ of the finalised draft local plan. (vii) Access and Infrastructure Requirements The Department is not aware of the proposal having any access or infrastructure implications. (viii) Methods of Operation (including lighting and noise) The Department is not aware that the proposed methods of operation would have any significant implications from a noise and lighting perspective

D. CONCLUSION

Through this consultation process the department has established that there are two key grounds for objection to this application: the adverse landscape and visual impact that will occur as a result of this proposed development, views supported by SNH; and the increased risk of disease spread between existing management areas and fish farms as a result of a fish farm at this location, this view is supported by SEERAD. Furthermore, there may be a limited adverse impact on tourism.

It is recommended that an objection be raised against this application on these grounds.

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APPENDIX 2 RELATIVE TO 06/00270/MFF

List of Objectors:

NAME ADDRESS DATE Secretary Clyde Fishermans Association PO Box 9261 Campbelltown P L M Stewart MBE PA28 6YE 15/03/2006 1 John Street Rothesay John Hutchings Isle Of Bute PA20 0HA 20/03/2006 101 High Street Rothesay The Dumbarton Hun Isle Of Bute PA20 9DB 10/03/2006 11 Auchnacloich Road Rothesay Duncan Reynolds Isle Of Bute PA20 0EB 20/03/2006 11 Auchnacloich Road Rothesay Laura Reynolds Isle Of Bute PA20 0EB 20/03/2006 11 Bush Avenue Rothesay S Booth Isle Of Bute PA20 20/03/2006 11 Bush Road Rothesay Peter MacKay Isle Of Bute PA20 9HS 20/03/2006 114 South Woodside Road Kelvinbridge Mr And Mrs Scott Glasgow G20 6NS 23/03/2006 119 Somerville Drive Aileen And Robert Bollan And Sylvia Carnwath Stewart Lanarkshire ML11 8JW 23/03/2006 12 Auchnaclloich Road Rothesay Mr Reynolds Isle Of Bute PA20 0ES 20/03/2006 12 Aauchnacloich Road Rothesay Mrs Agnes Reynolds Isle Of Bute PA20 0EB 20/03/2006 12 Terrace Ardbeg Isle Of Bute Owner/Occupier PA20 0NP 15/03/2006 122 Dora Road Wimbledon Park Mrs Lindsey Barraclough London SW19 7HJ 23/03/2006 13 Barone Road Rothesay James Morrison Isle Of Bute PA20 20/03/2006 13 Barone Road Rothesay S Morrrison Isle Of Bute PA20 20/03/2006 14 Craignethan Mountstuart Road Craigmore Rothesay Lynn Carson Isle Of Bute PA20 9LF 16/03/2006 15 Barone Road Rothesay Duncan McLean Isle Of Bute PA20 0DU 20/03/2006 15 Barone Road Rothesay I McLean Isle Of Bute PA20 0DU 20/03/2006 15 High Road Mr And Mrs Lockhart And Family Isle Of Bute PA20 0NY 13/03/2006 16 Mariners View Amble Mrs Louise Smith Northumberland NE65 0JH 22/03/2006

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16 Tower Street Rothesay Christine Aird Isle Of Bute PA20 0BZ 14/03/2006 17 Kirklee Circus Ilya Scott Glasgow G12 0TW 09/03/2006 19 Bishop Street Rothesay Helen And Malcolm Johnston Isle Of Bute PA20 9DH 22/03/2006 19 Winton Terrace Fairmilehead Murdo M Ross Edinburgh EH10 7AP 21/03/2006 2 Eden Place 179 High Street Rothesay Ian L Hopkins Isle Of Bute PA20 9BS 21/03/2006 2 Sycamore Rise Foulridge Colne Jan And Oliver Brabender Lancashire 23/03/2006 21 Bishop Street Rothesay Malcolm Johnston Isle Of Bute PA20 22/03/2006 21 Bishop Street Rothesay Mrs J F Johnston Isle Of Bute PA20 9DH 22/03/2006 21 Stockiemuir Court Stockiemuir Avenue Bearsden Mrs Hilary McNeil Glasgow G61 3AR 14/03/2006 22 Rosslyn Road Bearsden Mrs Angela Scott Glasgow G61 4DN 12/03/2006 23 Argyle Place Rothesay John Nelson Isle Of Bute PA20 0BA 13/03/2006 23 Argyle Place Rothesay Theresa Nelson Isle Of Bute PA20 0BA 23/03/2006 25 Windsor Gardens Largs Mike Johnston Ayrshire KA30 9DN 14/03/2006 26 Ardmory Road Ardbeg Mrs Margaret McVey Isle Of Bute PA20 0AP 16/03/2006 27 Argyle Place Rothesay Harry Lymburn Isle Of Bute PA20 0BA 13/03/2006 27 Argyle Place Rothesay Harry Lymburn Isle Of Bute PA20 0BA 30/03/2006 27 Columshill Street Rothesay Brian Barr Isle Of Bute PA20 0DN 16/03/2006 27 East Princes Street Rothesay Dave Finlayson Isle Of Bute PA20 9DL 16/03/2006 27 East Princes Street Rothesay Laura Finlayson Isle Of Bute PA20 9DL 16/03/2006 28 Ardbeg Road Rothesay Andrew And Susan McKay Isle Of Bute PA20 0NL 22/03/2006 3 Cumbre View The Wee Bay Kingarth David T Brown Isle Of Bute PA20 9NP 23/03/2006 3 St Johns Drive Rothesay Mr Thomas Strachan Isle Of Bute PA20 9JB 06/03/2006

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3 St Johns Drive Rothesay Thomas Strachan Isle Of Bute PA20 9JB 17/03/2006 326 West Princes Street Euan And Angela Petrie Glasgow G4 9HA 13/03/2006 39 Eden Drive Rothesay Bruce Bennett Isle Of Bute PA20 9HU 20/03/2006 39 Eden Drive Rothesay Carol Bennett Isle Of Bute PA20 9HU 20/03/2006 39 Longhill Terrace Rothesaay Jim Brown Isle Of Bute PA20 0JU 20/03/2006 4 Colenden Stormontfield Ian McLachlan Scott Perth PH2 6BL 10/03/2006 4 Coloenden Dtromontfield Ian McLachlan Scott Perth PH2 6BL 30/03/2006 42 Ardmory Road Rothesay OSheila Scott Isle Of Bute PA20 20/03/2006 42 Marine Road Port Bannatyne R Lawson Isle Of Bute 15/03/2006 49A Mountstuart Road Rothesay Andrew E Pearson Isle Of Bute PA20 9EB 20/03/2006 55 Eden Drive Rothesay Mrs Helen McKirdy Isle Of Bute PA20 20/03/2006 56 Ardbet Road Rothesay Mark Nicol Isle Of Bute PA20 0NL 16/03/2006 58A ARdbeg Road Rothesay Claire McTaggart Isle Of Bute PA20 0NN 20/03/2006 6 Fuschia Close Priorslee Geoffrey Leleux Twelford TF2 9PG 15/03/2006 60 Ardmory Road Rothesay Dot And Raymond Deans Isle Of Bute PA20 0PG 23/03/2006 68 Ardmory Road Ardbeg R Matts Isle Of Bute PA20 0PG 22/03/2006 68 St Helens Gate Huddersfield Peter And Mary McKenzie West Yorkshire 21/03/2006 7 Wyndham Road Ardbeg Rothesay A Morrison Isle Of Bute PA20 20/03/2006 8 Bellevue Road Rothesay Occupier Isle Of Bute PA20 0AT 20/03/2006 87 Ardbeg Road Rothesay Alison Clark Isle Of Bute PA20 0NW 14/03/2006 9 Craigmore Road Rothesay Margaret Brown Isle Of Bute PA20 0LB 13/03/2006 9 Foley Road Rothesay Mr D Kane Isle Of Bute PA20 9HR 23/03/2006 9 Greek Drive Rothesay Kathleen Reid Isle Of Bute PA20 0NU 20/03/2006

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9 Park Road Henley-On-Thames Mrs L Moore Oxon RG9 1DB 16/03/2006 91 Barone Road Rothesay Mrs Irene Russell Isle Of Bute PA20 0DZ 13/03/2006 Aros-na-Mara 8 Marine Place Rothesay Mr And Mrs Mackay Isle Of Bute PA20 0LF 21/03/2006 Arran View Serpentine Road Rothesay Martin McNee Isle Of Bute PA20 9EH 10/03/2006 Ballianlay Schoolhouse Rothesay Helen Robertson Isle Of Bute PA20 0QG 23/03/2006 Birchwood Glebelands Road Rothesay Archie McCabe Isle Of Bute PA20 9HW 20/03/2006 C/o Bogany Farm Rothesay Jim Reynolds Isle Of Bute PA20 20/03/2006 C/o Troon Yacht Haven Ltd The Harbour Troon Stephen Bennie Ayrshire KA10 6DJ 22/02/2006 Cherry Trees Rothessay Jan McKirdy Isle Of Bute PA20 9LE 11/03/2006 Chris Stewart Architects Top Floor Mercat Building 26 Gallowgate Chris Stewart Glasgow G1 5AB 08/03/2006 Clandale Eastlands Road Rothesay Alastair MacKenzie Isle Of Bute PA20 9EN 22/03/2006 Clandale Eastlands Road Rothesay Anne Film Isle Of Bute PA20 9EN 17/03/2006 Cliffside Kilchattan Bay Pam Armstrong Isle Of Bute PA20 9NW 20/03/2006 Clyde Fishermans Association PO Box 9261 Campbeltown Argyll P L M Stewart (Secretary) PA28 6YE 01/03/2006 Commodore Guest House Battery Place Rothesay Michael W Spear Isle Of Bute PA20 0DP 08/03/2006 Crossbeg Rothesay Rhod HB Lofting DL Isle Of Bute PA20 9PB 23/03/2006 Daisey Cottage St Ninians Bay Christine McArthur Isle Of Bute PA20 0QF 06/03/2006 Daisy Cottage Christine, Eilidh, Mhairi And Colin St Ninians Bay McArthur Isle Of Bute PA20 0QF 09/03/2006 Daisy Cottage St Ninians Bay Isle Of Bute Christina McArthur PA20 0QF 30/03/2006

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Delhi Cottage 19 Craigmore Road Rothesay Mrs Marion S Hanschell Isle Of Bute PA20 9LB 21/03/2006 Delhi Cottage 19 Craigmore Road Rothesay Isle Of Bute PA20 9LB D Hanschell 21/03/2006 Director Euroyachts Power And Sail 34 Earl Haig Road Hillington Industrial Estate R M Scott Glasgow G52 4JU 21/03/2006 Director Troon Yacht Haven Troon Yacht Haven Ltd The Harbour Troon Stephen Bennie Ayrshire KA10 6DJ 22/03/2006 Duchra Lochans Kathleen McHarrie And Family Stranraer DG9 9AZ 16/03/2006 Dunagoil Kingarth A J Steven Isle Of Bute PA20 9LX 22/03/2006 Dunnottar Academy Road Rothesay Mr John Glen Isle Of Bute PA20 0BG 22/03/2006 Dykenamar Shore Road Kilchattan Bay Mrs E Lofting Isle Of Bute PA20 9NW 23/03/2006 Elderslie Serpentine Road Rothesay Andy Walters Isle Of Bute PA20 9HG 23/03/2006 Elderslie Serpentine Road Rothesay Joan Walters Isle Of Bute PA20 9HG 19/03/2006 Eskdale 7 Bishop Terrace Rothesay Chris And Elizabeth Stewart-Moffitt Isle Of Bute PA20 9HF 16/03/2006 Ettrickdale House Port Bannatyne Dr Frank Ledwith Isle Of Bute PA20 0QZ 20/03/2006 Fauldmore Serpentine Road Rothesay Edwin Middleton Isle Of Bute PA20 9HG 21/03/2006 Flat 2/1 9Chapelhill Road Rothesay Isle Of Bute J M Robinson PA20 BJ 15/03/2006 Flat 2/1 2 Columshill Place Rothesay Mr Joseph Fraser Isle Of Bute PA20 0DL 20/03/2006 Flat Ground Left 27 Argyle Street Rothesay Fiona McArthur Isle Of Bute PA20 0AX 14/03/2006 Helenslea 46 Crichton Road Rothesay Graeme P Bartrop Isle Of Bute PA20 9JT 22/03/2006

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Ivy Rose Cottage The Straad Rothesay Anne Rado Isle Of Bute PA20 0QF 20/03/2006 Ivy Rose Cottage The Straad Rothesay Anne Rabo Isle Of Bute PA20 0QF 30/03/2006 Janette Cottage Townhead Rothesay Charles And Sheila Murray Isle Of Bute PA20 9JM 13/03/2006 Kames Castle Stuart And Lesley Scott Isle Of Bute PA20 0QP 22/03/2006 Kerrylamont Farm Mount Stuart Lynn T Henshelwood Isle Of Bute PA20 9LP 21/03/2006 Kerrylamont Farm Mount Stuart Robert Henshelwood Isle Of Bute PA20 9LP 22/03/2006 Kerrylamont Farm Mount Stuart Isle Of Bute Robert Henshelwood PA20 9LP 30/03/2006 Largs Yacht Haven Irvine Road Carolyn R Elder Largs KLA30 8EZ 22/03/2006 Little Kilmory Cottage Martin And Dorothy Cullinane Isle Of Bute PA20 21/03/2006 Little Kilmory Isle Of Bute Michael O'Loughlin PA20 0QA 08/03/2006 Lower Norwood Kilchattan Bay Isle Of Bute Miss I C McArthur PA20 9NG 17/03/2006 Lower Straad Cottage STraad Yennie Van Oostende Isle Of Bute PA20 0QF 10/03/2006 Mecknoch A Beverley And Petitioners Isle Of Bute PA20 0QA 23/03/2006 Mecknoch Isle Of Bute Amy Beverley PA20 0QA 08/03/2006 Mecknoch Isle Of Bute Angela Beverley PA20 0QA 07/03/2006 Milton Farm Rothesay June And Brian Passfield Isle Of Bute PA20 0QA 16/03/2006 Milton Farm Rothesay Priscilla Warren Isle Of Bute PA20 0QA 16/03/2006 Iain MacDonald No Address Given 14/03/2006 Oaklea Ministers Brae Rothesay Hugh Simpson Isle Of Bute PA20 20/03/2006 Orchardbank Dalshannon View Mr And Mrs David Forrest Cumbernauld G67 4DS 23/03/2006 Pier View Kilchattan Bay Tom Cromack Isle Of Bute PA20 9NW 23/03/2006 Pretoria 27 Argyle Terrace Ropthesay Isleo F Bute Mrs I F McArthur PA20 0BD 15/03/2006

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Quogach Farm Rothesay Mr Stuart Reid Isle Of Bute PA20 0QA 24/03/2006 Riversdale 36 Argyle Street Rothesay Hugh Cole Isle Of Bute PA20 0AX 23/03/2006 Rose Cottage Shore Road Port Bannatyne Richard Snape Isle Of Bute PA20 0LQ 17/03/2006 Seaview Cottage 46 Ardbeg Road Isle Of Bute Mrs M Chalet PA20 0NL 15/03/2006 Seaview Cottage 46 Ardbeg Road Rothesay Isle Of Bute Mr Adrian Chalet PA20 0NL 15/03/2006 Secretary Bute Community Council Craigielea Cottage Ardbeg Julian Hankinson Isle Of Bute PA20 0NL 23/03/2006 St Ninians Cottage Straad Lorna And James Mitchell Isle Of Bute PA20 0QF 14/03/2006 Stewart Hall Donald Campbell Isle Of Bute PA20 0QE 21/03/2006 Stuck Farm Rothesay Elizabeth Crawford Isle Of Bute PA20 0QL 22/03/2006 Stuck Farm Rothesay R W Crawford Isle Of Bute PA20 0QL 22/03/2006 Stuck Farm Rothesay Yvonne Crawford Isle Of Bute PA20 0QL 24/03/2006 Technical Manager Pan Fish Ltd Ardkinglas Estate Cairndow Alex Adrian Argyll PA26 8BH 22/03/2006 The Boat House Guest House 15 Battery Place Rothesay Sara Goss And Paul Melvin Isle Of Bute PA20 9DP 13/03/2006 Tramore Serpentine Road Rothesay Georgeann Martin Isle Of Bute 15/03/2006 Westwood Argyle Terrace Rothesay Maria Oostende PA20 0BE 15/03/2006 White Point Cottage St. Ninians Bay Straad Isle Of Bute Ronald Scott PA20 08/03/2006

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