Ardentinny-based environmental group, AFFtheClyde, has this week welcomed, with guarded optimism, the National Park recommendation that the proposed Loch Long Salmon (LLSC) Bienn Reithe fish farm near Arrochar’s planning application be refused.
Although the application has received support from some MSPs and local councillors, Loch Lomond and the Trossachs National Park received over 200 objections to what the developers have said “will be the largest salmon farm in Scotland by a considerable margin”.
AFFtheClyde group member Hilary Worton said “We are indeed pleased that the National Park Planning Officer is recommending that the application be refused. However, it will be up to the planning committee and the board to make the final decision. Therefore, this is not the end of the battle and our campaign will continue.”
“One thing to note from the report is that Loch Long Salmon apparently considered alternative sites but these were discounted. However, the National Park has stated in its report that it is difficult to conclude that Loch Long is a unique site to locate an ‘experimental’ farm considering sound evidence indicating that significant, irreversible damage could occur. One could also question this ‘unique’ site status when, in recent weeks, we have seen media reports quoting LLSC, that if the Loch Long application was successful, it could lead to 4 more semi-closed farms on the west coast of Scotland in the future.”
On the consultation process undertaken by the National Park Hilary Worton continued, “We consider that there has been a failure of the consultation process via community councils and a weakness of the process in sharing information and engaging with our communities. This has driven us to expand the AFFtheClyde network as a forum to connect the voices of opposition beyond its Ardentinny roots and encompass ordinary residents from all the Loch Long communities who will clearly be affected by this industrial development”.
In the 100+ page ‘Special Board Report’ published this week, National Park planners cited a number of reasons as to why the application should be refused including: that the development would have an industrial appearance in an area of undeveloped coastline; would not safeguard visual amenity and important views; and would not protect or enhance the rich landscape character of the National Park. The development would adversely impact the special landscape qualities for which the National Park has been designated and the Authority does not believe that the proposed development would contribute to sustainable development.
In addition, the report says “The development does not align with National Marine Plan Aquaculture Policy, which states that aquaculture developments should avoid and/or mitigate negative impacts on the seascape, landscape, and visual appeal of an area. Additionally, the proposed development does not align with the policy to maintain healthy salmon and diadromous fish stocks. The potential of further negative impacts on already fragile native fishes is a risk that cannot be accepted”. In its application, Loch Long Salmon proposed a time limited temporary consent of 20 years. However the Park did not consider this length of time temporary as it would not reduce the landscape impacts or adverse effects on wild fish.
The report also said that the presence of an industrial development could deter recreational users of the Loch or the paths in the area and the quality of the recreational experience would be diminished during the construction phase and operation of the fish farm. Many of those who objected to the plan highlighted concerns about the impact on both tourism and recreation.
The planners agreed with many who lodged objections to the development in that although the applicant considers the technology proven, the proposed tech has not been trialled in Scotland and there were inherent risks from an escape incident to wild salmon populations which are already fragile. Further, the use of Loch Long waters on an industrial scale would impact the habitats and species that rely on the marine environment and would negatively impact on the National Park’s natural resources.
The report also questioned the level of contribution the development would bring to the area, given that only 12 jobs would be generated locally, compared with the level of risk associated with the development and that there was no guarantee that the proposed roles would be filled by local people. Also mentioned was its effect on the Park’s long-term ambition to see more regular water transport for visitors to Loch Long to re-establish historical connections from Glasgow to Arrochar.
The Park authority disagreed with LLSC statements that the development aligns with the National Park’s crucial role in tackling the climate emergency. In the report the Park says it recognises the fragile state of the precious nature of the National Park and its objectives are indeed to go further than protecting habitats and species but by reversing decline and restoring nature. The risk to wild salmonid from the proposed development does not align with these issues.
Marine Scotland Science (MSS) pointed out that they were unable to complete an assessment of terms of the mooring analysis and containment as LLS had failed to submit a mooring analysis which includes the four marine enclosures and a harvesting enclosure, as detailed in the planning application. MSS were therefore unable to advise that the mooring grid and lines would be suitable.
NatureScot stated that, while literature suggests that the technology is effective in reducing sea lice levels, they anticipate that the technology is still likely to ensure low levels of sea lice within the cages which could lead to the possibility of sea lice being dispersed south to the Firth of Clyde and therefore potential connectivity with the Atlantic salmon of the Endrick Water special area of conservation.
The report concludes that the proposed development would be contrary to the first, second and third statutory aims of The National Park (as set out in section 1 of The National Parks (Scotland) Act 2000). The National Park Authority must, in its determination of the application, give greater weight to the first aim “to conserve and enhance the natural and cultural heritage of the area” as it is in conflict with the fourth aim.
Following a prior site visit in the morning, a National Park Authority Special Board Meeting will take place at Three Villages Hall, Arrochar at 14:00 on 31 October, 2022. Members of the public may apply to speak (see below).
For more information on the planning application see https://eplanning.lochlomond-trossachs.org/OnlinePlanning/ (Ref: 2021/0357/DET).
SPEAK AT THE PUBLIC HEARING
Anyone or organisation who wishes to speak at the Pre-determination Hearing to the Board must submit a speaker participation form by email or in writing to the Committee Clerk no later than 12 noon on Monday 24th October 2022. The speaker participation form is available here.
VISIT THE PROPOSED FISH FARM SITE AND ATTEND THE PUBLIC HEARING – FREE COACH TRANSPORT. MONDAY, OCTOBER 31, 2022, 10:20 AM – 5:30 PM
A public hearing in respect of the planning proposal for an industrial-sized, semi-closed fish farm at the head of Loch Long (Beinn Reithe) will take place at Three Villages Hall, Shore Road, Arrochar, G83 7AB on Monday 31 October, 2022, 2pm. The meeting will be preceded by a visit to the proposed site at 10.20am by the National Park Board and the public. It is vital that as many as possible from our communities attend the meeting on the day to demonstrate the strong opposition that exists against what will be the largest fish farm development in Scotland.
AFFtheClyde is arranging free coach transport from Ardentinny, Lochgoilhead/ Carrick Castle, Cove/Kilcreggan/Roseneath, Garelochhead and Portincaple. There may also be the possibility of collection in Dunoon. Coach collection times will be confirmed shortly.
If you would like to take part in opposing this massive development and be collected from any of the above locations, please email afftheclyde@gmail.com with your name, location and mobile phone number. We will confirm the transport as soon as possible.