Objections Summary

The main grounds of Objection

In the pages which follow you will find the detailed arguments which will be put to the various decision makers when the application goes to a hearing. They are briefly summarised here as:-

Economic grounds.

This development would damage the main driver of the local micro-economy, the leisure and tourism industry, being sited in the very heart of one of Scotland’s most precious and most-visited areas of scenic beauty and heritage. The small number of jobs on offer would be quite inadequate to make up for the likely losses to the existing businesses that are currently struggling in the recession. The blunt fact is that the development is simply in the wrong place. Read more on Economic Objections here

Science and the Environment

The immediate area is an established run for sea trout, wild salmon, dolphins and seals, as well as seabirds and other maritime flora and fauna. It is on the edge of the Firth of Lorn Special Area of Conservation and entitled to protection under European Directives. Rather than adopting modern methods of double-netting the applicants intend to get a licence to shoot seals and scare off dolphins, porpoises etcetera with acoustic devices. Read more on this here.

The Threat to Navigation

Seil Sound and Cuan Sound are widely used by commercial and pleasure vessels travelling between Crinan to the South, Loch Melfort to the East, Balivicar to the North and Oban and the Hebrides to the North. Effectively blocking about one half of the navigable channel would present a real threat to safety. Read more on the Threat to navigation here.

Quality of Life

The proposal involves placing intrusive industrial structures in the middle of an outstanding area, steeped in culture and history. The noise from the operation of generators night and day and light pollution from underwater lighting would cause distress and annoyance to residents and visitors alike. To read more about this, click here

Relocation or a new proposal?

The applicants have described the proposal as a “relocation” rather than a new installation, because if it is granted they will close down their existing operation further North in the Seil Sound. We argue that this description is misleading, because:-

1    Although only 1 kilometre to the south 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 consists of eighteen square cages in two rows, occupying a much smaller area of sea. The new farm would contain two rows, each of six circular cages, described as 100 metres circumference, that is about 32 metres diameter, occupying an area of the surface of the sea of approximately 30,000 square metres, with in addition the space occupied by the service barge referred to below. The overall area involved, including mooring equipment, amounts to 179,800 square metres of seabed.

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 some of 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. artists impression of structure

4    The existing unit has a maximum permitted biomass of 1,350 tonnes, whereas the new one would be 2,500 tonnes. This corresponds to about 450,000 adult salmon. The equivalent human population would correspond to a small city with about 130,000 inhabitants.

5    The proposed underwater lighting between the months of December and May and the use of “approved acoustic deterrents may be used if and when required” have environmental and social implications that are not present on the existing site.

6    The application does not fully illustrate the impact that the proposed development would have on safe navigation. 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.

7    The skerries in nearby Cuan Sound are an important pupping area for harbour seals. The Southern boundary of the Lorn Special Area of Conservation begins about 1500 metres away at the Cleit Rock in the Cuan Sound.

Another issue will arise in future, if the applicants get planning permission and put in an application to the Crown Estate Commissioners. 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. Thus they describe as “existing” something which does not exist and has never existed. The Commissioners retain the power to terminate a lease if it is not taken up and it’s surprising that they haven’t done so here.
Apparently the applicants have acquired the shellfish lease and propose “to change the lease area and type of farming operation at Ardmaddy South from mussels to salmon.” This is also strange, as fish farm leases and shellfish leases are two quite distinct types. The extent of the amendments sought suggest that this should be viewed by the Crown Estate Commissioners in due course as an entirely new application, rather than for consent to a simple assignation. Which will the applicants apply for?

We argue that the above features sufficiently distinguish the new proposal from the existing one to make this effectively a new proposal, in terms both of planning and Crown Estate rules.