SEPA Ardmaddy call-in Request refused - Press Release

[NickB]

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This is a press release from the 'Save Seil Sound' campaign:

Bad news for Ardmaddy

The Scottish Ministers, presumably in the person of the new Environment Minister Paul Wheelhouse, decided this week not to call in Lakeland Marine Farm’s application to SEPA for a licence to dump effluent and other toxic materials in the Seil Sound from a proposed industrial installation housing up to 2,500 tonnes of salmon, equivalent to a population of 600,000 mature fish.

Those who have been following the saga of Ardmaddy will know the history. The story started in the early 2000s when an installation at Loch Riddon was found to be polluting to such an extent that the local wild salmon population had effectively become extinct and there was a lot of pressure for it to be removed. Following a series of working group meetings among representatives of Scottish Government, the industry and wild fish interests it was decided to move the facility by adding it to the existing Pan Fish unit at Ardmaddy, near the North end of Seil Sound. Residents of Seil were not consulted. After some intense lobbying Argyll & Bute Council duly granted planning consent for this under the fast-track delegated procedure without a public hearing and SEPA granted a discharge consent, technically termed a CAR licence.

In granting the CAR licence SEPA relied on a computer modelling system known as Autodepomod, whereby factors such as known tidal stream data, seabed conditions and quantities are inputted and the computer makes a prediction of the amount of pollution, i.e. toxic chemicals, faecal waste, uneaten food and so on, that the local ecology can handle. Fish “farming” is one of the few industries that are permitted by law actively to pollute the environment, but a company may only do so within an area known as the “allowable zone of effects” (aze).

After a few years it became clear from reports filed by the operating company with SEPA that the unit at Ardmaddy was polluting way beyond the permitted aze. The most likely cause was the fact that tidal streams had proved much stronger than previously thought, carrying waste particles suspended in water way beyond the aze. Everyone knows that if flawed data is inputted to a computer the results will also be flawed. “Rubbish in rubbish out” proved to be literally true at Ardmaddy.

The sensible option might have been to reduce production from the polluting level of 1,300 tonnes to the previous 800 tonnes, at which the reports filed by Pan Fish had indicated “acceptable” levels of pollution. As an alternative the company, now Lakeland Marine Farm Limited, decided to relocate to another site a little further South, opposite the entrance to the Cuan Sound. To do so they required, in addition to planning consent, a fresh CAR licence.

The applications were duly made, but not just for permission to produce 1,300 tonnes. Instead Lakeland sought permission to produced 2,500 tonnes. The basis for this was an assessment made by, you’ve guessed it, the same Autodepomod computer modelling system that had failed at the original site. In fact 2,500 tonnes is the current maximum that the computer modelling can handle and accordingly the maximum that SEPA can consider consenting.

One does not need to be opposed to fish farming in general to find this deeply disturbing. Nor does the fact that computer modelling failed at Ardmaddy mean that the entire Autodepomod system is flawed. In suitable locations, where tidal streams have been accurately plotted and the local seabed conditions and geography properly assessed it may well be fine. Sea lochs are known to be tricky and treated as such by the system, but incredibly Seil Sound is not officially viewed as a sea loch. I suspect that the respectable scientists who developed Autodepomod as a useful tool would not disagree and would be concerned that the reputation of their product was being put at risk by its use in an inappropriate location.

In deciding to back SEPA in its total reliance on the computer Scottish Ministers have lost a valuable opportunity to have the process thoroughly investigated via an inquiry before an independent reporter, hearing evidence from marine and scientific experts. This would have been helpful, not only in safeguarding the local ecology at Seil, but to the aquaculture industry in general.

All of this says nothing about the other issues involved, apart from pollution. Lakeland Marine Farm shoot seals and they want a licence to do so at Ardmaddy. They may use acoustic scaring devices, despite evidence in research sponsored by the government itself that these damage other protected species such as porpoises and dolphins. Incredibly, SEPA do not consider sea-lice to be pollution, so the effects on wild fish have not been assessed by them at all. Under European legislation there should have been environmental assessments into all these matters.

These general concerns have been recognised by Mike Russell MSP. In a letter to Argyll & Bute Council he wrote inter alia that “The grounds for objection are many and varied and include damage to tourism, loss of navigable water, possible danger to wildlife and interruption to kayaking which has grown greatly in the area and detriment to the special area of conservation.”

The final decision will now be left to Argyll & Bute Council when the matter comes back to the planning committee. The planning application attracted about 800 objections and was put on hold to allow the pollution issues to be resolved. The planning officers and the elected members will do their best, but they will do so knowing that there is a huge question mark hanging over the methodology adopted by SEPA and with the limited resources available to them in these cash-strapped times.

To finish by quoting Mike Russell again “at the very least there should be a public local inquiry,” precisely what the Scottish Ministers have now ruled out in refusing to call in the CAR application.
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www.saveseilsound.org.uk

[NickB]

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And here's what happened . . . . as reported by someone who attended the planning meeting today:

This week there was a good chance to see democracy in action, Argyll style, at the Corran Halls when the PPSL Committee met to decide the controversial application for a 600,000 capacity fish farm in Seil Sound.

The application had attracted about 800 objections, of which over 100 came from residents of Seil, Easdale and Luing, representing about a quarter of the adult population. A further 140 or so came from mid-Argyll, another 125 from the rest of Scotland and about 350 from the rest of the United Kingdom, many of them holiday visitors, and 65 came from abroad. There were also 44 letters in support, of which one was from a local resident.

Those who have been following this saga will know that some years ago Ardmaddy was selected as a “pilot relocation project” by the Scottish Government to receive a transfer of the total production from a site in Loch Riddon, which had been polluting to such an extent that much of the wildlife there had become extinct. As a result the site at Ardmaddy had its capacity increased from 800 tonnes (200,000 fish) to 1300 tonnes (325,000 fish) but it was soon found that the natural capacity of the environment
could not cope, as the strong tidal streams round the top of Seil Sound were carrying away huge quantities of fish waste, toxic chemicals and pesticides with some ending up in the nearby Firth of Lorn, which enjoys special protection under the European Habitats Directive.

Faced with having to relocate the operating company decided not only to move further South down the Sound but to apply for an increase of permitted biomass at the same time, to a total of 2,500 tonnes. Representing 600,000 mature salmon, this is the maximum that can currently be licensed for any farm in Scotland.

As consultees the Argyll Fisheries Board argued that it would be better to relocate without simultaneously increasing the biomass, to discover if the new site was truly better than the existing one. This would seem to be the prudent scientific way to do things, but wasn’t to be.

Although the major problems with large scale industrial fish farms are to do with pollution and waste disposal it seems that Argyll & Bute Council has convinced itself that such matters have nothing to do with the planning process. Astonishingly (and perhaps to the surprise of the applicants) the Council decided it was unnecessary to require an Environmental Impact Assessment.

Accordingly the issue came down to one of jobs – preserving employment in the operating company and its suppliers versus the threat perceived by the local residents, and expressed in their strong objections, to their own jobs in tourism and leisure based businesses. Here we saw some instances of local democracy at its very worst.

A supporter of the application claimed that unlike fish farming, tourism employs mainly “folk from Eastern Europe”. Underlying some councillors’ remarks seemed to be a feeling that jobs in tourism don’t count. There used to be a feeling that it was somehow demeaning to work in a service industry rather than to do “real work” such as in agriculture and fisheries and one would have hoped that such days were long gone.

Councillor Devon let slip her feelings in asking for figures about “your tourism” as if the industry is a trivial local thing: one would have thought that a politician would know that the sector is bigger by far than any other outside the public sector, generating, according to Scottish Government figures 130 times more revenue than aquaculture does.

Councillor Currie spoke strongly in support of the application, despite knowing that his home community of Islay had protected their jobs by seeing off efforts by a fish farm company to establish a similar operation there (746 locals plus 102 visitors signed the petition against). Perhaps he’s hoping that the people back home don’t get to hear how he voted.

At the end of the day not one of the committee found any merit whatsoever in the points put forward on behalf of the residents of Seil and the application was granted unanimously.

This closes a chapter in the story of fish farming around Seil, but the book isn’t written yet. This week also saw an application going in to SEPA for yet another 2,500 tonne installation in a proposed new site off the bay at the South west corner of the Isle of Shuna.

[jimcee]

I always thought that our councillors were supposed to reflect the interests and concerns of the people who elected them to the "gravy train".
From the number of objections and minimal support for this proposal it would appear that they had other "Fish to Fry".
One despairs.

[Seventhseil]

Whether or not you support the fish farm, the understanding of how a planning application works seems to be at fault. Its my understanding that objections from those not in the imediate vacinity or owning property in the vacinity of the of application are not taken into consideration. Therefore, all those objections that were not from seil, and perhaps even some from Mid argyll would have been void...... wasting both Save Seil Sound & A&B councils time. So of the 200 or so left, may be 50% are non planning related objections. Not Objections that should be ignored, but not relavent to the planning proccess. That leaves approx 100 vs 44, again letters of support are not really in the scope of a planning application. So if the council believe the company have adressed the objections raised (rightly or wrongly) the application will go through.

[NickB]

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Just reading in today's Herald that three of the local fish farms in Loch Shuna - Port Na Cro, Poll Na Gile and Bagh Dail nan Ceann - have all shown levels of the pesticide emamectin in sediment in breach of SEPA's permitted levels. Apparently this pesticide - and others used to treat sea lice - is highly toxic to crabs and prawns.

It would seem extraordinary if the proposed new fish farm farm still goes ahead in the light of these findings. I wonder though if this was known about before last week's meeting.