As outlined in our article of September 13, 2021, SEPA is to grant a licence for the proposed Dawnfresh Ardentinny fish farm subject to the conditions in the draft authorisation. Although SEPA advised that they had lost the contact details of those who had made representations in June 2019 due to a cyberattack in December, 2020, we now understand that they hand-wrote the initials and surname of the respondent on each representation printout prior to the cyberattack, therefore SEPA should be aware as to the names of each of the 26 respondents.
SEPA promised in its new regulatory framework to properly involve communities in the decision-making process when their local waters are going to be polluted by aquaculture. There has been no attempt by SEPA to involve the local Ardentinny community or undertake consultation events or provide the community with the information needed to assess the impact of the proposed fish farm. The cyberattack in December should not be an excuse to cheat communities of the only chance they have to understand and comment on the proposed environmental pollution.
With regard to the SEPA report on the issues raised by representees, we have requested from SEPA the following:
– Can SEPA confirm that the installation will be the same size as proposed for the original 2000 tonnes max biomass CAR application?
– Can SEPA confirm that SEPA have applied their New DEPOMOD model based on the above?
– There is no mention of the use of in-feed emamectin benzoate to treat sea lice. Has Dawnfresh stated that this will not be used?
– We have requested a copy of the seabed survey which we understand was undertaken to assess biodiversity of the benthic communities.
– We have requested information on the pesticide dispersion modelling and the New Depomod particulate dispersion modelling.
– Marine Scotland’s dissolved nutrient calculations.
We have asked as to why SEPA does not assess eutrophication of the whole Greater Clyde system, by the 16 fish farms that are already there. Loch Long is not an isolated body of water.
– We have asked why SEPA will not postpone this determination as it is aware that increasing the biomass farmed fish in the Greater Clyde system will increase the cumulative impact of sea lice affect on wild salmon smolts from the Endrick Water Special Area for Conservation. Salmon are also a PMF. The report does not mention them but does say that mobile species, such as fish, can avoid the harm. This is not the case. Viable sea lice larvae from a farm can be transported 30km and migrating wild salmon cannot avoid them.
Planning Application:
We understand that, from a planning perspective, Loch Lomond & the Trossachs National Park has nothing new to report regarding the Dawnfresh Ardentinny proposals. The last communication in January, 2021 was related to a Dawnfresh request for advice toward preparing viewpoints for a Landscape and Visual Impact Assessment as part of a prospective planning application submission.
Representees:
Please note that SEPA will only accept copies of representations (by October 1, 2021) from the 26 who submitted representations in June, 2019. Please see https://afftheclyde.org/sepa-to-grant-licence-for-ardentinny-fish-farm/ for more information.
What to do next?
If you have a concern as to how the Ardentinny Fish Farm proposal has been dealt with by SEPA, please send a polite message to any of the following:
Terry A’Hearn, SEPA Chief Executive
McAllan M (Mairi), MSP Minister for Environment and Land Reform
Mairi Gougeon MSP Cabinet Secretary for Rural Affairs & Islands
Jenni Minto MSP Argyll & Bute
Burgess A (Ariane), MSP Greens MSP Highlands
Cameron D (Donald), MSP Scottish Conservative MSP for the Highlands and Islands
Halcro Johnston J (Jamie), MSP Highlands and Islands. Shadow Minister for Business, Trade, Tourism and Enterprise
Grant R (Rhoda), MSP Scottish Labour MSP for the Highlands and Islands
Mountain E (Edward), MSP Conservative and Unionist, Highlands and Islands
Councillor Gordon Blair SNP – Cowal
Councillor Yvonne McNeilly Conservative – Cowal
Councillor Alan Reid Liberal Democrats – Cowal
Please also continue to sign and share our 38degrees Petition as well as following and sharing our Facebook page, Facebook Group, Twitter and Instagram social media accounts for the latest updates.