|Castle of the Dogs|
In February, by good chance, I received a copy of a pre-application consultation in connection with a proposal to site a salmon farm at Ardmaddy in the Seil Sound, an area of outstanding landscape beauty and historical significance and lying within both the Knapdale/Melfort Regional Scenic Area and the Firth of Lorn Marine Conservation Area. The above image shows the view across the location, with the medieval hunting lodge the Castle of the Dogs in the foreground and just out of view across the Sound the prehistoric fortress of Dun Fadha.
I posted on this back in February and my efforts can be read here:- Proposed salmon farm at Ardmaddy and here:- Bad Neighbours
I promised to let people know if and when a formal application was lodged. In Argyll public notification is made through that august publication the Oban Times and it seems that a minute notice appeared, buried near the end of the paper, on 7 July, asking for any objections to be lodged within 21 days, making a deadline of 27 July to be on the safe side.
It is of course notorious for contentious applications to be made just after the start of the holiday period, when many are away and others have children at home and I confess that I missed it until last night, so there's less than a week before the period for comments closes. Argyll & Bute planners sent out letters to various statutory consultees on 6 July with the same deadline, stating that failure to reply would be taken to mean the bodies concerned had no objection. Their staff will also be affected by holidays and anyone working in the tourist industry is going flat-out at this time of year, so it won't be surprising if many of them miss out.
If you feel as strongly as I do about the destruction of our major asset, the environment with its unique beauty and wild-life please take the time to register your view. You can do so by clicking here:- Argyll & Bute Council website link for comments
In case it assists here is what I posted on the site:-
"I object most strongly to this application. My grounds of objection are:-
1 The siting of this massive development in a much-used stretch of water presents a serious hazard to the life and safety of all who navigate on or otherwise use these waters, be they small boat enthusiasts, canoeists, yachtsmen, divers or whatever. Blocking one half of a passage which forms a main route North comes close to infringing the public’s inalienable right to navigate.
2 The development will present a shocking eyesore in an area of panoramic beauty, which currently presents a major attraction to visitors.
3 The development will cause major pollution to Loch Melfort, already burdened by a significant number of other fish farms.
4 The presence of large numbers of captive salmon will threaten the health and welfare of the wild sea trout, shellfish and other wild-life in the area.
I have received an email from David Ainsley, a Seil resident and marine biologist, who runs Sea Life Adventures, a business bringing our countryside to life for visitors. Here is what he wrote:-
5 The proposal by the applicants to apply for a licence to shoot the local seal population is abhorrent."
"Save Argyll seals, wild salmon and help tourism
A planning application has been lodged to double the peak biomass of salmon (to 2500 tonnes) and slightly relocate the salmon farm at Ardmaddy, near Oban and close to the Firth of Lorn Special Area of Conservation. This farm is in a narrow channel used by migratory salmon and sea trout which have no choice but to pass so close to the farm that up to 80% may be killed by sea lice (Ref.3). There is an important seal pupping haulout close by in Cuan Sound. The farm proposes not to use environmentally friendly double nets but instead to shoot seals. When mother seals are shot the pups are left to starve. The farm will also use seal scarers - a known threat to bottlenose dolphins and porpoise which regularly use the Sound and are important to local tourism jobs. One report [ref. 1] estimates that the farm will produce pollution equivalent to the untreated sewage of a town of 50,000 people (Oban population is 8,120). There will be a feed barge, generator running at night and 24,000 watts of underwater lighting. The area within the buoyage will take up half Seil Sound in this beautiful scenic area.
Please spare 2 minutes to object to this application in order to save seals, wild salmon and the natural beauty of the area.
To object, copy the skeleton letter (or write your own)
then click on the link below and follow the simple instructions
Skeleton Letter. Copy the text from between the lines:
I object to the proposal. The doubling of biomass will increase problems caused by the existing farm, which would be better relocated offshore where there is the potential to expand with lesser impacts on wild salmon and sea trout, seals, bottlenose dolphins and porpoise. The proposal will also damage an important dive site (with a priority marine feature), the Firth of Lorn Special Area of Conservation, designated shellfish waters & wildlife tourism.
I request that an EIA and Appropriate Assessment be carried out and that the same legislation which required spending £11 million on Seil sewerage be applied.
This is a sensitive area of natural beauty. The concrete feed-barge, underwater lighting with generator at night and mooring buoys halfway across the channel will impair views.
If consent is granted, I request that conditions include: the fitting of double nets (outer and inner mesh identical), no seal shooting or use of seal scarers and no increase of biomass from existing farm.
Click the link below to see a video of a polluted seabed near a salmon farm in Argyll:
Thank you for helping. Please feel free to forward this e-mail to others.
For those who want more information David has also supplied the following:-
The technology now exists for the salmon farming industry to situate new farms offshore in areas less damaging to wildlife and tourism jobs. To operate in a more environmentally friendly way, the applicant (a large multi-national company) could relocate offshore, away from areas important to conservation and use double underwater netting (with the outer net mesh the same type and size as the inner net to prevent entanglement of wildlife). There would then be no need to shoot seals, and the double nets would also reduce the problem of farmed salmon escaping and damaging wild stocks. Instead, the applicant has chosen the cheaper option of applying for a site in a sensitive area important to wildlife, using single nets and shooting seals.
The farm is close to an important seal pupping ground around Cleit Rock in Cuan Sound. When mothers are shot, orphaned pups are left to starve. Under the Marine (Scotland) Act 2010, guidelines state that seals should only be shot as a "last resort". This application does not propose to fit double nets and therefore will not employ the most efficient non-lethal means of keeping salmon and seals separated. Accordingly seal shooting by this farm is not a "last resort" and the farm should not be granted a license to shoot seals.
The farm will also use seal-scarers, which are known to disturb dolphins and porpoise which regularly use the Sound. This may well change their migration patterns and impact on wildlife tourism jobs not to mention the good effect that seeing dolphins regularly has on the local community.
The application is for an inshore location in Seil Sound, which is a narrow channel used by migrating salmonids where sea lice and disease from the farm will continue to damage local salmon and sea trout stocks (Ref.3). There is no excuse for expanding without regard to local wildlife and tourist interests as these companies are currently highly profitable - one company reporting first quarter profits this year of over £1 million per 1000 tonnes of salmon farmed.
Historically, local rivers had healthy runs of salmon and sea trout. There used to be a bag-netting station at Easdale and the coble at Loch Feochan. The Rivers and Fisheries Trusts of Scotland (RAFTS) blame sea lice infestations from salmon farms for infecting migrating wild salmon and sea trout. They report that wild salmon rod catches between 1970 and 2009 in the West Highlands and Islands (the aquaculture area) have declined by 42%, whereas catches in the East, where there are no salmon farms, have risen by 24% [ref. 2]. Studies show that as many as 80% of juvenile salmon and sea trout are killed by sea lice from salmon farms [ref. 3].
The visual impact of the farm will detract from an area of great scenic beauty. Should consent be granted, the area within the moorings would be greater than the existing farm by a factor of 3.2 and the buoys would be halfway across the channel. There would be a large concrete feed-barge and 24,000 watts of underwater lighting with a generator running all night.
One report [ref. 1] estimates that the farm will produce pollution equivalent to the untreated sewage of a town of 50,000 people (Oban population is 8,120). Although salmon farms may not look particularly large, a huge biomass of fish is crammed into them. The proposed peak stocking density of 17.4 Kg / cubic metre exceeds the RSPCA "freedom foods" standards. On the 26th of April 2006, the applicant pleaded guilty to over-stocking fish cages and polluting the environment on their neighbouring site in Loch Shuna, and was fined £1000. Inevitably, pollution from the proposed site will reach both the local designated shellfish waters and the Firth of Lorn Special Area of Conservation yet no Appropriate Assessment (as required by the Habitats Directive) or Environmental Impact Assessment has been carried out. It was deemed necessary to spend £11 million to improve the sewerage of around 150 houses to comply with legislation - should the same legislation apply here?
The farm will be located very close to an important dive-site, which contains a "Priority Marine Feature" - an area of white cluster anemones (Parazoanthus anguicomus).
All public bodies have statutory duty under the Nature Conservation Act (Scotland) 2004, to 'further the conservation of biodiversity' as they carry out their work. There is a great deal of environmental legislation designed to protect biodiversity, seals, wild salmon, porpoises and dolphins, and the Firth of Lorn SAC. To this date, this legislation has not been correctly applied. It is important to note that the normal burden of proof in planning is reversed under the Habitats Directive. It is the responsibility of the appropriate authority of the member state to demonstrate that a "plan or project" will not adversely affect a Special Area of Conservation.
The Crown Estate owns the seabed. The views and the wildlife, which will be damaged should this application be approved, belong to the people of Scotland. If the application is approved, the planning consent alone will be worth perhaps £ millions to the applicant. People have a right to expect that the salmon farming industry will work to reduce its impacts on landscape and wildlife. This is not an environmentally responsible application. Please object to it.
[ref. 1] The One That Got Away (June 2001) by Friends of the Earth Scotland
[ref. 2] Comparison of the decline of Scottish East and West Coast Salmon Fisheries (June 2011) by RAFTS
[ref. 3] Year Zero For Wild Scottish Salmon (2010) by Salmon and Trout Association
Don't forget, there's less than a week to comment. Register your comment by clicking here:- Argyll & Bute Council website address for comments