DEVELOPMENT SERVICES Local Member - Councillor A Macaskill PLANNING APPLICATION REPORT Date of Validity - 21st January 2004 , LORN AND THE ISLES Committee Date - 5th May 2004

15th April 2004

Reference Number: 04/00112/MFF Applicants Name: Celtic Sea Ltd Application Type: Marine fish Farm Consultation Application Description: Proposed Shellfish farm Location: Loch Melfort, Kilmelford

(A ) THE APPLICATION

Works subject of Marine Fish Farm Consultation Procedure.

• Site A: Siting of 10 mussel longlines each @ 220 metres; and • Site B: Siting of 10 mussel longlines each @ 220 metres.

(B ) RECOMMENDATION

It is recommended that objections be raised to the proposal.

(C ) DETERMINING ISSUES AND MATERIAL CONSIDERATIONS

Material Considerations

It is proposed to form two new mussel farms within Loch Melfort, both of which to be operated by Celtic Sea Ltd who have an existing land base at . Site A is located to the immediate north east of Eilean Gamhna, just off Arduaine Point, and Site B is located to the north of this on the southern coastline of the Degnish peninsular, to the west of Kilchoan Bay.

Scottish Executive Locational Guidelines for Marine Fish Farming

The site lies within a Category 3 Area as defined in the Scottish Executive’s Locational Guidelines for the Authorisations of Marine Farms in Scottish Waters. Within this area there is considered to be better prospects for satisfying nutrient loading and benthic impact requirements although the detailed circumstances will always need to be examined carefully. As the proposed sites are for shellfish farms, the categories do not apply due to the marginal effect of this sector.

Adopted Lorn Local Plan

Policy RUR 16 of the Lorn Local Plan states that the Council will regard coastal waters adjoining land recognised as being of scenic importance in policy RUR 1 as being ‘sensitive areas’ for fish-farm developments. In these waters, the presumption will be against such development unless it can be justified against the following criteria:

i. Landscape Impact ii. Economic Benefit iii. Effect on conservation of natural and heritage resources iv. Effect on navigation and on other land/water uses and resources.

See below for full assessment. (Draft and Bute Local Plan)

Approved Structure Plan 2002

Proposal CP 1 of the Argyll and Bute Structure Plan states that the Argyll and Bute Local Plan shall include appropriate policies relating to shellfish and fin-fish farming, and that the policies will accord

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with the principles and categories contained in “Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters” issued by the Scottish Executive. See above:

Draft Argyll and Bute Local Plan 2003 The proposed sites lie within a ‘presumption in favour zone’ as identified by the Policy AQ 1 of the Draft Local Plan. Whilst there is an initial presumption in favour of marine fish farming in this particular area, this is conditional on the proposal meeting the criteria set out in Policy AQ 1; namely not having an unacceptable environmental, servicing or infrastructure impact; being consistent with the Scottish Executives strategic framework, guidelines and advice on fish farming; and being consistent with agreements covering the area. i. Landscape Impact and Visual Amenity

The proposal comprises of two sites for 10 mussel lines each, at the mouth of Loch Melfort. There is a fairly high level of aquaculture development within Loch Melfort itself and the adjoining Shuna Sound and the Seil Sound, and one key element in the assessment of this proposal is ensuring the fragile balance between the rural landscape and the industrialised elements is not upset, as equipment from modern shellfish farms can be visually dominant in the landscape due to the large floats used on the longlines.

Site 1 lies to the immediate north east of Eilean Gamhna, with lies almost at the centre of the entrance to Loch Melfort. This site occupies a very conspicuous location within the loch and will be openly visible to public view from Arduaine Gardens, the A816 and the Degnish Road, and from the loch itself, which has a high proportion of users due to the location of the boat yard and moorings at Kilmelford. The proposed site will be a prominent feature in the landscape, as the proposal for this site does not have an adequate backdrop of coastline, does not allow for the diminishing effect of distance due to its central position within the Loch and can be viewed from numerous significant viewpoints. It is considered that, as a stand-alone proposal, and when viewed cumulatively with the existing aquaculture development, a shellfish farm on site 1 would have a significant adverse impact on the landscape character of this area.

Site 2 lies near the mouth of Loch Melfort along the south eastern coast of the Degnish peninsula, to the immediate south west of Kilchoan Bay. This area of the Degnish peninsula has a very rural, undeveloped character. Whilst from long distance views from across the Loch, the proposed site would have little visual impact, from more immediate views around Kilchoan Bay and from the higher ground of the southern portion of the Degnish peninsula, the proposed site would be very visible and would add a significant manmade feature into this remote rural coastline. It is considered that this proposal would detract from the rural character of this area and, in light of the current level of aquaculture development in the area would, cumulatively, adversely affect the character of the Loch Melfort by upsetting the balance between the rural and industrial areas.

ii. Economic Benefit The applicant has advised that at present they are unable to keep up with the demand for fresh rope grown mussels therefore further farm sites are required. They have further advised that the direct benefits of these two new sites will be to secure the companies long term future and that of the existing 8 staff. The new sites in Loch Melfort will also require an additional 6 fulltime staff plus shore bases staff. They have advised that the indirect benefits would be the employment and wealth created in the industries peripheral to their own. These include transport services, fuel suppliers, mussel farming equipment suppliers, boat builders, engineering services etc. all of these supplies and services are sourced locally where possible. iii. Effect on conservation of natural and heritage resources

Scottish Natural Heritage has advised as follows:

Loch Melfort is within the Firth of Lorn Marine Consultation Area. There are several survey sites within the vicinity of the proposed sites. None of these show any habitats or species of conservation significance.

Eilean Gamhna is a mixed breeding colony for seabirds. This could potentially include terns which are a Schedule 1 species under the Wildlife and Countryside Act 1981 and are also afforded protection under the European Habitats and Birds Directive. In order to protect this site SNH has recommended a number of conditions. F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000245\M00001571\AI00016645\0112WR020304VER20.DOC 2

iv. Effect on navigation and on other land/water uses and resources. The Royal Yachting Association has raised objection to the proposals. Proposed site 1 would represent a hazard to navigation and would partially obstruct a widely used passage both to the north and the south of the proposed site. Site 2 is an established anchorage. Similar concerns/objections have been received from the Scottish Executive Fisheries and Rural Affairs Group, the Clyde Fishermen’s Association and the local community. In this respect the proposal is considered to represent a hazard to navigation and as such cannot be justified as it is contrary to the Governments Planning Advice Note on Marine Fish Farming and the Environment which advises that it is essential that marine fish farm development does not constitute a hazard to navigation and the established anchorages should be safeguarded.

Objections to the proposal have been received from the Scottish Executive and the Clyde Fishermen’s Association (CFA) in relation to the loss of prawn trawling grounds, and from a local fisherman over the progressive restriction of fishing opportunities due to the existing and proposed farms in the area. The CFA has advised that Loch Melfort is host to prolific prawn fishing, however, the possibility of trawling in Loch Melfort has been seriously restricted by the growth of aquaculture and creel fishery. The sites proposed in this current application will impact on at least two tows in the loch. The CFA has advised that they would be willing to discuss with the applicant a modification of the proposal that avoids interfering with the prawn fishery. In light of the impact on the existing fishing interests in the area, it is considered the proposal will have a negative impact on other land/water uses and resources. v. Effect on water quality. The Scottish Environmental Protection Agency and the Scottish Executive Fisheries and Rural Development Group have raised no objection to these proposals on the issue of water quality. vi. Infrastructure and Servicing Implications. The proposed sites could be serviced by the applicant’s existing land base at Arduaine. This has the appropriate planning permission. The proposal therefore raises no servicing or infrastructure concerns. vii. Effect on existing aquaculture development. The Scottish Executive’s Fisheries and Rural Development Group has advised that they do not anticipate any significant environmental impact and can foresee no adverse disease implications which may arise from the development. It is however recommended that management agreements are entered into with other operators sharing the same area, i.e. the Seil Sound to Loch Craignish management area.

(D ) CONCLUSION

The proposal will: • have an adverse impact on safe navigation in Loch Melfort; • negatively affect the prawn fishery interests in Loch Melfort; and • have an adverse impact on the landscape quality of this area.

The proposal is therefore considered to be contrary to Policies RUR 16 of the Adopted Lorn Local Plan; PROP CP 1 of the Approved Argyll and Bute Structure Plan; Policy AQ 1 of the draft Argyll and Bute Local Plan and Government guidance contained within Advice Note: Marine Fish Farming and the Environment.

Angus J Gilmour Head of Planning

Contact: John Maciver 01631 567951

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REASONS FOR OBJECTION RELATIVE TO APPLICATION 04/00112/MFF

1. Site 1 lies to the immediate north east of Eilean Gamhna, which lies almost at the centre of the entrance to Loch Melfort. This site occupies a very conspicuous location within the loch and will be openly visible to public view from Arduaine Gardens, the A816 and the Degnish Road, and from the loch itself, which has a high proportion of users due to the location of the boat yard and moorings at Kilmelford. The proposed site will be a prominent feature in the landscape, as the proposal for this site does not have an adequate backdrop of coastline, does not allow for the diminishing effect of distance due to its central position within the Loch and can be viewed from numerous significant viewpoints. Both individually and cumulatively, with the existing level of aquaculture in the area, the development of a shellfish farm on site 1 would have a significant adverse impact on the landscape character of this area. The proposal is therefore contrary to Policy RUR 16 of the adopted Lorn Local Plan; Policy CP 1 of the Approved Argyll and Bute Local Plan; Policy AQ 1 of the Draft Argyll and Bute Local Plan and the Governments Advice Note: ‘Marine Fish Farming and the Environment’, all of which have a presumption against aquaculture development which would have an unacceptable environmental impact.

2. Site 2 lies near the mouth of Loch Melfort along the south eastern coast of the Degnish peninsula, to the immediate south west of Kilchoan Bay. This area of the Degnish peninsula has a very rural, undeveloped character. Whilst from long distance views from across the Loch, the proposed site would have little visual impact, from more immediate views around Kilchoan Bay and from the higher ground of the southern portion of the Degnish peninsula, the proposed site would be very visible and would add a significant manmade feature into this remote rural coastline. Both individually and cumulatively, with the existing level of aquaculture in the area, the development of a shellfish farm on site 2 would have a significant adverse impact on the landscape character of this area. The proposal is therefore contrary to Policy RUR 16 of the adopted Lorn Local Plan; Policy CP 1 of the Approved Argyll and Bute Local Plan; Policy AQ 1 of the Draft Argyll and Bute Local Plan and the Governments Advice Note: ‘Marine Fish Farming and the Environment’, all of which have a presumption against aquaculture development which would have an unacceptable environmental impact.

3. A shellfish farm of the scale proposed on Site 1 would partially obstruct a widely used passage both to the north and the south of the proposed site. In this respect the proposal is considered to represent a hazard to navigation and as such cannot be justified as it is contrary to the Government’s Planning Advice Note on Marine Fish Farming and the Environment which advises that it is essential that marine fish farm development does not constitute a hazard to navigation and the established anchorages should be safeguarded. The proposal is therefore contrary to Policy RUR 16 of the adopted Lorn Local Plan; Policy CP 1 of the Approved Argyll and Bute Local Plan; Policy AQ 1 of the Draft Argyll and Bute Local Plan and the Governments Advice Note: ‘Marine Fish Farming and the Environment’, all of which have a presumption against aquaculture development which have a negative impact on navigation.

4. A shellfish farm of the scale proposed on Site 2 would undermine the use of an established anchorage. In this respect the proposal is considered to represent a hazard to navigation and as such cannot be justified as it is contrary to the Government’s Planning Advice Note on Marine Fish Farming and the Environment which advises that it is essential that marine fish farm development does not constitute a hazard to navigation and the established anchorages should be safeguarded. The proposal is therefore contrary to Policy RUR 16 of the adopted Lorn Local Plan; Policy CP 1 of the Approved Argyll and Bute Local Plan; Policy AQ 1 of the Draft Argyll and Bute Local Plan and the Governments Advice Note: ‘Marine Fish Farming and the Environment’, all of which have a presumption against aquaculture development which have a negative impact on navigation.

5. Shellfish farms on both Site 1 and Site 2 would result in the loss of prawn trawling grounds and local fishing grounds. In this respect the proposal is contrary to the Government’s Planning Advice Note on Marine Fish Farming and the Environment which advises that care must be taken to minimise the potential for conflict between marine fish farming and local fishing interests. The proposal is therefore contrary to Policy RUR 16 of the adopted Lorn Local Plan; Policy CP 1 of the Approved Argyll and Bute Local Plan; Policy AQ 1 of the Draft Argyll and Bute Local Plan and the Governments Advice Note: ‘Marine Fish Farming and the Environment’, all of which have a presumption against aquaculture development which have a negative impact on other land/water uses and resources.

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APPENDIX RELATIVE TO 04/00112/MFF

(A) POLICY OVERVIEW

In terms of Section 25 of the Act the following Development Plan Policies are applicable:

Approved Argyll and Bute Structure Plan

PROP CP 1 Aquaculture and Development Control

A) the Argyll and Bute Local Plan shall include appropriate policies relating to shellfish and fin-fish farming. B) The policies will accord with the principles and categories contained in “Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish Waters” issues by the Scottish Executive.

Adopted Lorn Local Plan

RUR 16 The Council will regard coastal waters adjoining land recognised as being of scenic importance in policy RUR 1 as being ‘sensitive areas’ for fish-farm developments. In these waters, the presumption will be against such development unless it can be justified against the following criteria:

i. Landscape impact ii. Economic benefit iii. Effect on conservation of natural and heritage resources iv. Effect on navigation and on other land/water uses and resources.

Draft Argyll and Bute Local Plan

AQ 1 Marine Fish Farming

A) In coastal waters within the ‘presumption in favour zone’ and on adjacent land, there is support in principle for shellfish and fin-fish farming. This support is conditional on the proposal:

1. not having, directly or cumulatively, unacceptable environmental, servicing or access impact. 2. being consistent with the Scottish Executive strategic framework, guidelines and advice on fish farming. 3. being consistent with agreements covering the area which may be reached between partners and the planning authority as part of the coastal framework plan process.

B) Other than in exceptional circumstances, shellfish and fin-fish farming shall be resistant in coastal waters within the ‘coastal constraints zone’.

(B) OTHER MATERIAL CONSIDERATIONS

(i) Site History

None specific to these proposed sites.

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(ii) Consultations

Response Date Comment Scottish Environmental 19.2.04 No objections Protection Agency Royal Yachting Association 24.2.04 Objections raised on navigational grounds. Scottish Natural Heritage 16.2.04 No objection subject to conditions RSPB 25.1.04 No objection subject to conditions Scottish Executive Fisheries & 17.2.04 No objections objection on disease grounds, Rural Development Group however objections raised on loss of fishing grounds for local fishermen and for navigation reasons. Kilninver and Kilmelford 11.2.04 Objections raised for following reasons: Community Council • resultant destruction of balance between industry and tourism. • visual impact. • navigation concerns. • Loch Melfort is unsuited to shellfish production. • proposals will obstruct existing loch users. • impact on existing fish farms. • Impact on wildlife. • concerns over actual employment generation from the proposed development.

Clyde Fishermen’s Association 29.1.04 and Objections raised on the grounds of loss of 10.2.04. trawl grounds for existing prawn fishermen and navigation.

(iii) Publicity and Representations

Advert Type: Advert in accordance with the Interim Procedures. Closing Date: 19th February 2004

Representations: Yes

Name Address Letter date K.G. Pollard Kilmelford, PA34 4XA Feb 2004 P.M Dines CBE Applegarth, Middleton, Pickering, N.Yorks, 24.02.04 YO18 8NU James M Irvine Kintyre, 5 Bruce Place, Oldmeldrum, INVERURIE, 24.02.04 AB51 0GU S. Morley Alafoss, Cuilfail Terrace, Kilmelford, OBAN, 31.01.04 & PA34 4XH 22.02.04 Mr & Mrs Taylor Hadley Brae, Ford, , PA31 8EH 22.02.04 R Lindsay Elder 6 Chapelton Gardens, Bearsden, GLASGOW, 21.02.04 G61 2DH Dr John S. Reid Rochelle, Old Inn Road. Findon, Portlethen, 21.02.04 ABERDEEN, AB12 3RT D.J. & A.D.S. Munro 37 Summergate Road, ANNAN, DG12 6EX 21.02.04 Mr & Mrs K Urquhart Lilac Cottage, CARRBRIDGE, PH23 3BX 20.02.04 Mrs Bridget P. Oatts South Wing, Glenmore, Kilmelford, OBAN, 21.02.04 PA34 4XA R.W. Douglas Paterson Old Mill House, Wargrave-on-Thames, 24.02.04 BERKSHIRE, RG10 8DE J. Brown 8 Corrennie Gardens, EDINBURGH, EH10 6DG 22.02.04 Richard W. Murray 69 Swarthmore Road, Selly Oak, BIRMINGHAM, 21.02.04 B29 4NH John R Swannie Salisbury View, Bodkin Lane, Out Rawcliffe, 23.02.04

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PRESTON, PR3 6TL John R Trusting Hill House, Carlton, Bedfordshire, MK43 7ND 24.02.04 J & E Tickle Brewery House, Foston on the Wolds, Driffield, 23.02.04 East Yorkshire, YO25 8BP J.W.B. Snaith The Old Hall, High Coniscliffe, DARLINGTON, 23.02.04 DL2 2LF Douglas Smith North Barn, The Green, Drayton, ABINGDON, 24.02.04 OX14 4HZ Professor S C Hughes East Lodge, Asknish, Lochgair, LOCHGILPHEAD, 24.02.04 PA31 8SB F.S. Morrison Air Tir, Balvicar, OBAN, PA34 4TF 25.02.04 Dr Rob Smith 1 Whitefauld Road, DUNDEE, DD2 1RH 23.02.04 Fiona Wyllie Traighuaine, Arduaine, OBAN, PA34 4XQ 30.01.04 Hugh D Campbell- Tighnamara, Kilmelford, OBAN, PA34 4XD 02.02.04 Gibson Alex Adrian Pan Fish, Ardkinglas, CAIRNDOW, PA26 8BH 26.01.04 Mr & Mrs Asbury Achnacille, Kilmelford, OBAN, PA34 4XD 24.01.04 Duncan J. MacLean 32 Langdon Park Road, Highgate, LONDON, 22.01.04 N6 5QG H.R. Keate Kilchoan House, Kilmelford, OBAN, PA34 4XD 26.01.04 K.J. Scaife Fearnach House, Kilmelford, OBAN, PA34 4XD 22.01.04 & 16.02.04 David M. Wilkie Ardfern Yacht Centre Ltd, Ardfern, 27.01.04 LOCHGILPHEAD, PA31 8QN Dr J C A Craik Grendon, Barcaldine, OBAN, PA37 1SG 26.01.04 Stuart G Cannon Kames Fish Farming Ltd, Kilmelford, OBAN, 30.01.04 PA34 4XA J. Keate Kilchoan Farm, Kilmelford, OBAN, PA34 4XD 22.02.04 Ewan G Kennedy Faulds Gibson Kennedy, 23 Royal Exchange 06.02.04 Director Square, GLASGOW, G1 3AJ John C Christlieb Melfort Pier, Kilmelford, OBAN, PA34 4XD 05.02.04 & 09.02.04 Etonella Christlieb Melfort Pier and Harbour, Kilmelford, OBAN, 05.02.04 PA34 4XD J Corley The Peels, Harbottle, MORPETH, NE65 7DL 04.02.04 Claire Corley The Peels, Harbottle, MORPETH, NE65 7DL Undated Robert Corley The Peels, Harbottle, MORPETH, NE65 7DL 04.02.04 Thomas Corley The Peels, Harbottle, MORPETH, NE65 7DL Undated Jane Dallas Ross 23 Havelock Street, GLASGOW, G11 5JF 05.02.04 Mrs D. S. Carmichael Kilbrannan, Kilmelford, OBAN, PA34 4XF 02.02.04 Shian MacLean Tullich Farms, Kilmelford, OBAN, PA34 4XA Undated Diane Scaife Fearnach House, Kilmelford, OBAN, PA34 4XD 12.02.04 Irene Murray Ardmore, Crannaig-a-Mhinister, OBAN, PA34 4LX 18.02.04 C & J Gladstone Tullich Farms, Kilmelford, OBAN, PA34 4XA 17.02.04 Iain, Malcolm, Dorothy & Lochend, Kilmelford, OBAN, PA34 4XD 15.02.04 Mary Bark G Dalton Maolachy, Lochavich, TAYNUILT, PA35 1HJ 16.02.04 Clare Howard Scarba, Arduaine, OBAN, PA34 4XQ 16.02.04 Neil Manchester Eas a’ mhuilinn, Kilmelford, OBAN, PA34 4XA 16.02.04 Ian N. Tegner Keepers Cottage Kilninver, OBAN, PA34 4UT 17.02.04 S MacLean Tullich Farms, Kilmelford, OBAN, PA34 4XA Undated Catherine Manchester Eas a’ mhuilinn, Kilmelford, OBAN, PA34 4XA 16.02.04 Julietta St. John Tullich Farms, Kilmelford, OBAN, PA34 4XA 17.02.04 Christine Roberts Melfort Village, Kilmelford, OBAN, PA34 4XD 20.02.04 P.J. Boddy 33A Combie Street, OBAN, PA34 4HS 22.02.04 K.G. McColl Kilmelford Yacht Haven, Kilmelford, OBAN, 19.02.04 PA34 4XD Graham Pinch 11 Homer Avenue, Tarleton, PRESTON, PR4 6DB 27.02.04 John Nuttall Charon, Norton Fitzwarren, Taunton, Somerset. 23.02.04 Hamish Graham Woodville, 22 Havelock Street, HELENSBURGH, 29.02.04 G84 7HQ

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Owner/occupier 18 Porthill Road, SHREWSBURY, SY3 5SE 24.02.04 D Jamieson Stetind, Inch Avenue, Aberdour, BURNTISLAND, 27.02.04 KY3 0TF David Stone 30 Summerside Street, EDINBURGH, EH6 4NU 02.03.04 John Walbaum The Schoolhouse, Broughton, BIGGAR, MU2 6HQ 04.03.04 Mrs M Cross Little Torwood, The Glebe, Kilmelford, OBAN, 13.03.04 PA34 4XF David M. Wilkie Ardrowan, Kilmelford, OBAN, PA34 4XA 06.03.04 Prof Colin Davidson West Highland Anchorages and Moorings 26.01.04, Secretary & Treasurer Association, Tigh-nan-Eilean, Ardfern, 02.02.04 & LOCHGILPHEAD, PA31 8QN 07.03.04 Mairi McPhie Drissaig, Lochavich, TAYNUILT, PA35 1HJ 02.03.04 Maurice H Whittle 89 Coppice Road, Poyton, Cheshire, SK12 1SL 01.03.04 Alice McPhie 9 Cuilfail Cottages, Kilmelford, OBAN, PA34 4XB 02.03.04 Lindsay Clark 8 Cuilfail Cottages, Kilmelford, OBAN, PA34 4XB Feb 2004 John & Jane Rentoul Laroch, Kilmelford, OBAN, PA34 4XA 01.03.04 W.G. Staff The Birks, Silverdale Road, ARNSIDE, Cumbria, 03.03.04 LA5 0EH J P Stannard Seall-na-Mara, Arduaine, OBAN, PA34 4XQ 18.02.04 Owner/occupier 37 Northide, Hutton Radby, YARM, TS15 0DA 28.02.04 C.R. Carmichael Allt Na Crioch, Kilmelford, OBAN, PA34 4XD 15.03.04 Dr Andrew K Zealley 12 Tipperlinn Road, EDINBURGH, EH10 5ET 03.04.04 John Carmichael 6 Maryfield Road, Broughty Ferry, DUNDEE, 26.03.04 DD5 2JJ

Summary of points raised:

• Impact on tourism interests, including yachting and water sport activity. • Concerns over negative impact on navigational safety. • Concerns over impact on existing fishing grounds, and possible resultant job losses. • Concerns that the currently acceptable balance between tourism and industry would be destroyed. • Concerns over visual impact of the proposal. • Concerns that the proposal will result in little, if any, increase in local employment. • Impact on wildlife interests. • Local environment is not suited to shellfish production. • Environmental Impact Assessment should be required. • Concerns raised in respect of the over-commercialisation of this area and the potential for increased disturbance and commercial litter as a result. • Concerns raised over potential disease risk. • Concerns raised over pollution and the detoxification processes at Arduaine . • Concerns raised over the procedures for removal of equipment at cessation of business, liability insurance and the transfer of licences.

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