Sunday, 7 August 2011

Ardmaddy Fish Farm - Briefing Notes

View of the threatened site
Update as at 18 August 2011

Since these notes were prepared the campaign group has set up where there are now comprehensive pages incorporating everything in the notes and much more besides. Also the group has received more information about the proposal and a number of points have been cleared up.

In particular the applicants have confirmed that when they referred to the "existing" installation in their application they were referring not to their existing operation further North but to a proposed mussel farm for which a local fisherman got a licence from the Crown Estate many years ago, but never actually constructed. Accordingly what they described as existing didn't exist and what did exist wasn't described.
The applicants have now provided details of their existing farm, in the sense of the one that really, actually does exist in the real world, which can be read about on the new website. What follows is the text of my original post. Please follow for developments and updates.
I have prepared these notes for the assistance of those who are just joining the 400 or so people who have already made their views known to Argyll & Bute Council and also as an aide memoire for the rest of us.
The proposal

The operators of an existing salmon farm at Ardmaddy Bay in the Seil Sound, Argyll propose to close down that facility and open a new one further South in the Sound. They describe this as a proposed "relocation" but arguably this is misleading, because:-

1 Although not far distant the new site is much more prominent and conspicuous. It is in the centre of one of Argyll's finest visual panoramas, much visited by tourists and close to the Cuan Sound, which is believed to form a major run for the local wild fish population and is much used by passing commercial vessels and yachts.
2 The existing farm is said by the applicants to consist of six square fish cages, each ten metres by ten metres The new farm would contain two rows, each of six circular cages, described as 100 metres circumference, that is about 32 metres diameter, increasing the area involved from 55,803 square metres to 179,800 square metres. I'm not a great expert on football pitches, Olympic swimming pools or the size of Wales, but this seems a massive increase, by a factor of 3.2.
3 The existing operation is serviced by boats from Craobh Haven and the applicant's base in Loch Craignish. The new one would involve a concrete feeder and servicing barge of which the dimensions are given in one of the applicant's supporting documents. The proposed barge is rectangular and has a deck area of 26 metres by 18 metres. On top there are a number of units, including a feed silo and a personnel room with on top of this a further deck area surrounded by railings, giving a total height of about 3 metres. The structure would be built from grey concrete and surrounded by tyre fenders.
4 The existing unit has a maximum permitted biomass of 1,350 tonnes, whereas the new one would be 2,500 tonnes.
5 The proposed new unit would involve underwater lighting between the months of December and May, consisting of 2 x 1,000 watt lamps per cage powered by a diesel-fuelled generator on the barge.
6 To scare off wild-life "approved acoustic deterrents may be used if and when required."

I suggest that these features sufficiently distinguish the new proposal from the existing one to make this effectively a new proposal and not a relocation.

Further misleading statements.

The applicants state that the site has an "existing use" as a mussel farm. It is true that a local fisherman got a lease from the Crown Estate many years ago for this site (and two others) for this purpose, but he never operated the site as such. This statement may be calculated to make anyone unfamiliar with the locus think there is an operation there already. I am unable to see why else it was made.

What is relevant, but the applicants don't refer to it, is that many years ago Pan Fish Scotland were scoping this site for salmon farming and rejected it after local objections, some based on the fact that the adjacent bay was seen as a "harbour of refuge."
The applicants state:- "A Farm Management Agreement has been defined for this area and has been signed by Lakeland Marine Farm and Kames Limited." This is no doubt true but is not the whole story. There was a "Lower Lorn Area Management Agreement" in place between 2006 and the end of 2010, but it collapsed, per the Atlantic Salmon Trust:-
"Now the Lower Lorn AMA has collapsed, after wild fish interests in Argyll decided they could no longer support it. The Association of Salmon Fishery Boards (ASFB) says that this calls into question the viability of the entire policy.
The collapse is blamed on the 'serial failure of one side to the agreement to honour its commitments.' "
While the agreement between the two companies is better than nothing this history does nothing to inspire confidence. Area Management Agreements are a key part of the Scottish Government's strategy for controlling the spread of infection and sea lice and the lack of one in a largely contained stretch of water such as Loch Melfort is highly disturbing.

Nor for that matter does it inspire confidence that Lakeland Marine Farm Limited were in 2006 fined for the criminal offence of over-stocking their unit at Shuna.

Full details of the proposal and the comments received by Argyll & Bute Council can be found online here:- 

 The benefits of the proposal.
Farmed fish are by far the largest export from the Scottish economy by value at the present time, bringing in great sums to local economies not just in terms of direct employment but in the supporting industries and the spin-off multiplier effect beloved by economists. One consequence of this is that there is undoubtedly pressure on government bodies to downplay the side effects.

In the present case the applicants claim that the proposal will support "3 to 4 full-time and two part-time employees." Even in terms of the micro-economy in this part of Argyll this does not seem a lot. The automatic feeding system makes the unit less labour-intensive than a traditional unit.

One thing that will not happen is for any of the profit to stay in Scotland, or indeed in the UK. Lakeland Marine Farm Limited is owned by Morpol, an operation with numerous foreign shareholders, but mainly owned from Poland. You can inspect the list of shareholders here:-
The Grounds of Objection
The Science
As with many scientific issues where money is involved there is a furious debate about why our native fish stocks on the West coast are in proven, serious decline. Wild salmon are apparently plentiful in our great Northern and Eastern rivers where, surprise, surprise, there are no fish farms.

Marine biologists are providing convincing evidence of cross-infection between caged fish and wild stocks not just when the former escape but with the spread of the deadly sea-lice.

Many experts are worried that our waters could experience catastrophic increases of lice, one describing our sea-lochs as "bombing alleys."

The routine anti-biotic treatment of caged fish leads to the development of super-viruses.

The quantity of salmon faeces produced by 2,500 tonnes of salmon (about 400,000 fish) is equivalent to that produced by a town many times the size of Oban. Richard Pierce has calculated that the total human population of Seil has a weight of about fifteen tonnes. And the government spent eleven (or was it eighteen) million Pounds on a sewage system for them to keep our seas clean!

Very little is known about the behaviour patterns of our native sea-trout. There still are some in Loch Melfort and it is known that they run in Seil Sound.

How much pollution can the site in Ardmaddy take? I am informed that the bottom is rocky and so less able to take the constant dumping of waste food and faeces. By contrast, with a sediment bottom marine borers come to the surface and diligently clear up the mess left by human enterprise.

Finally to those who say we must eat something and why not salmon we must respond with the question "what do the salmon feed on?"

The most widely-accepted opinion seems to be that it takes three tonnes of fish-meal to produce one tonne of salmon. The fish-meal consists of sand-eels and similar fish that have been hoovered from the sea-bed, dried and processed. As fish are themselves mainly water it must take several tonnes of fish to create one tonne of meal. The industry itself claims a conversion ration of about 1.5 to 1, which seems improbable but is still inefficient.

Incidentally the destruction of sand-eels impacts on the populations of sea-birds and marine mammals too.

There is a helpful and highly readable article about all this available online here:-

Last, but I hope not least, some may spare a thought for the wretched salmon thrashing about in the cages. A very senior former government adviser in these matters considers "farming" a misnomer and told me that caged feeding would be a better term.

To all of this the industry will say, either that its methods are perfectly safe and there are other reasons for the loss of our wild fauna, or that these having already been destroyed there is nothing left to damage.

I am frankly astonished that Argyll & Bute Council appear to have decided that an Environmental Impact Assessment is not required in this case and have asked the planning officer in charge to explain the reasoning behind this. Others with better scientific knowledge than I have are also asking more detailed questions about this.

We can't expect too much from our national politicians, but local ones should be very concerned indeed about our ecology and the impact its destruction would have on our main local industry, tourism.

While salmon-farming is important nationally tourism is the main driver of our local economy in Argyll. Including its supporting industries it employs by far the greatest number of our private sector workers.

Increasingly foreign visitors are coming to see Scotland's unique ecosystems, often bringing with them canoes and bicycles to explore her remote corners. Those of us lucky enough to be here year-round perhaps become used to the scenery, but to visitors from, say, the industrial heartland of Germany or the intensively-farmed flatlands of the Netherlands it presents breathtaking views of the unspoilt fringe of Europe.

Yachting has a traditionally elitist image, but water sport in all its forms, be it small boating, canoeing, diving or indeed yachting has always been one of the major pastimes of our island nation. Increasingly people are trailer-sailing, bringing small relatively inexpensive craft with them. There are also our excellent facilities for sea trips to see seals, dolphins, birds and other wild-life.

Bluntly, fish-farming and tourism don't mix. The sites are ugly and industrial and you won't see a lot of seals near them, because operators shoot them. (The present applicants have declared their intention to seek a shooting licence.)

In the present recession parts of our tourism industry are struggling and it's vitally important not to damage them further. This should be the main focus of our objections, as the threat to the local economy should be pretty obvious to both the planning officials and members of the planning committee.

Public Health and Safety

Seil Sound and Cuan Sound are in constant use by commercial fishermen, pleasure boats and yachts and excursion boats. Ardmaddy is a favourite spot for the Hebridean Princess and the Waverley occasionally passes near.

The proposal would make the only bay nearby effectively inaccessible, denying the harbour of refuge that was the basis for then Scottish-owned Pan Fish withdrawing years ago.

More than one half of the navigable part of the Seil Sound would be out of bounds. Just beyond the site the apparently clear part contains dangerous unmarked rocks. Richard Pierce has contributed the following:-

"This is the only sheltered safe beach landing / anchorage/ refuge in many miles of otherwise hostile coastline.  Its orientation, and position provide an unusually well protected refuge in all wind directions and tide conditions, particularly for the ever increasing number of cruising yachts and small cruise ships visiting the area....
I am concerned that by omission, the application does not fully illustrate the impact that the proposed development would have on safe navigation. For instance the submitted chart is cropped in such a way that anyone unfamiliar with the area will see no potential hazards. Reading the chart in the way a mariner does, to plot his course or safe refuge, requires a more extensive view....[which shows]... that no other vessel can anchor not only in the black zone, but in a significant region beyond, for fear of fouling anchor warps on mooring lines.                                                                 
This mooring area will thus preclude other vessels from anchoring in the shelter of Torsa from the prevailing SW and NE gales.
...from the scans it is difficult to appreciate the hazards to navigation to the North East Torsa at the entrance to the fiercely tidal Cuan Sound."
In the online version of this Richard has posted some images that clearly illustrate his point. He has also posted a photograph of a stranded yacht with the words:-

"This recent RNLI rescue was effected just a few hundred metres to the NW of the proposed cages. The unmarked submerged rocks are in what would appear to be the centre of the 'new' fairway. Thankfully these visitors made their mistake in calm weather."
You can read Richard's full posting and see the photographs here:-

This is not just posturing by demented yachties. Visitors to our waters, even from as near as the Firth of Clyde, often don't appreciate the hazards presented by Argyll's unmarked reefs and isolated rocks. The public have the right to use the sea for the purposes of both navigation and leisure. This is inalienable, that is to say the Crown Estate Commissioners do not have the power to take it away, although in the past they have come close to doing so.
Quality of Life

I have left this to the end, because I suspect a decision will be made on economic rather than on the unquantifiable effect of forcing local residents to endure constant noise, artificial light and water pollution. For local residents the effects of the development, apart from the obvious visual one, would be:-
1 The constant background noise from the day-round operation of diesel generators. The existing one at the North end of Shuna can be heard thumping all day from miles away. On Luing recently I heard locals remarking that the noise had actually stopped for a short period!
2 Periodic noise from the helicopters and supply vessels. Those of us already experiencing these know how intense the disturbance can be.
3 Lack of access to a beautiful stretch of water and shore for fishing and pleasure boating.
4 Light pollution from the underwater installations. A major joy of country living is the darkness of our winter nights.
5 Loss of wild life, resulting form the shooting of seals and the acoustic scaring devices.
6 Pollution of the sea caused by food debris and faeces.
The Irony

What is depressing about this application is that the interests of fish-farmers and others such as tourists and local residents only come into conflict when one intrudes on the territory of another. By locating farms in remote locations far away from centres of tourism and population the problems seen with this application would largely be avoided. Further the most modern and enlightened methods of fish farming incorporate:-
1 Locations on the open sea, where sea-lice is less of a problem.
2 The use of double-netting, which minimises the risk of escapes and makes it unnecessary to shoot seals.
3 Locating the units on land, or developing enclosed sea-based units where the environment can be totally contained. This puts the farmer in total control of the nurture and health of his product.
I owe a great debt of gratitude to numerous people who have helped me to put these notes together. I have taken a lot of care with the text and have tried to make it as accurate as possible, but if you spot anything that should be questioned or corrected please let me know.
I'm posting the notes up on, where comments can be made, anonymously if people wish (although that is obviously not my preferred option) or I can be emailed on ewangkennedy@gmail,com.
As comments come in I will edit the text as appropriate, so that it remains up to date and accurate.
Notes prepared by Ewan G Kennedy, Kilmelford, 7 August 2011

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The Wherrymen
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