20-01345-MFF - SR no.2
Argyll and Bute Council · 24 May 2023
Back to Planning, Protective Services and Licensing Committee — 24 May 2023 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Argyll and Bute Council Development and Economic Growth Delegated or Committee Planning Application Report and Report of Handling as required by Schedule 2 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 relative to applications for Planning Permission or Planning Permission in Principle _________________________________________________________________________ Reference No: 20/01345/MFF Planning Hierarchy: Local Application Applicant: MOWI Scotland Ltd. Proposal: Formation of fish farm (Atlantic Salmon) incorporating twelve 120m circumference circular cages and siting of feed barge Site Address: North Kilbrannan Fish Farm, North of Cour Bay, Kilbrannan Sound, East Kintyre ________________________________________________________________________ SUPPLEMENTARY REPORT NO. 2 1.0 INTRODUCTION The purpose of this report is to make Members aware of an additional letter received from the applicant dated 23/5/23 in response to late representations. 2.0 DETAIL The letter dated 23/5/23 advises that Mowi would like to take the opportunity to respond to the three last minute objections to the North Kilbrannan Fish Farm, which have been submitted within two days prior to the Planning Committee meeting scheduled for 24/05/2023. They are surprised and disappointed by the nature of the last minute attempts to lobby the council planners and councillors with these objections which they consider are largely based on personal opinion, lack scientific evidence, and are indeed false. Additionally, they do not find the threatening undertones acceptable. They contend that an example of the false statements made in these objections include the suggestion that a Google Maps Satellite image can display “large quantities of visible pollution flowing out of that [Carradale] site”. Having looked at the current Google Maps Satellite, which will not be updated to real-time, it is clear that this image displays natural water movement and eddying as a result of vessel movement and current displacement from the infrastructure. Mowi rigorously adheres to strict licence conditions relating to discharge into the marine environment and finds this potentially defamatory claim unacceptable. With regards to comments made by Ms Burgess MSP on the cumulative impact of sea lice from the proposed North Kilbrannan Fish Farm with the existing farms in Loch Fyne and the Firth of Clyde, MOWI agree and recognise that this is an important assessment to make. They have already taken this into account and submitted cumulative modelling of existing sites within the Firth of Clyde and the proposed North Kilbrannan Fish Farm (dated 12 April 2021). As detailed in this cumulative assessment of all active fish farms in the Clyde area, modelling results show that levels of sea lice occur at low densities (less than 0.1 lice m-2) throughout most of the Firth of Clyde and Kilbrannan Sound. Technical details of this modelling can be
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reviewed on Argyll and Bute’s planning portal and MOWI would be happy to answer any further questions on our cumulative sea lice modelling if needed. Additional comments made by Ms Burgess MSP refer to Sea Lice modelling carried out by SEPA. MOWI note that the comments do not quote a source document, and the applicant is not aware of finalised results or a published report by SEPA. They believe that this calls into question the source, accuracy, and reasonableness of the information stated as fact. They note that SEPA has engaged with the industry as part of the consultation process developing the Sea Lice Risk Framework and that SEPA’s modelling is a screening tool and as a result is conservative. MOWI do not consider that it is appropriate to base the North Kilbrannan decision on a screening tool, particularly one which is not finalised, published, or accepted in regulation. Once a protocol is developed, finalised detailed modelling would be required in addition to the screening tool, which would take into account factors such as lice behaviour and would present more realistic results. Preliminary work by the industry and independent parties replicating SEPA’s tool and comparisons with more realistic modelling outputs have shown lower lice burdens that the screening results. Considering the comments made by Ms Burgess, MOWI find it inappropriate for an MSP to intervene at such a late stage with comments that have previously been discussed. MOWI suggest a recourse to the parliamentary standards committee might be appropriate. The applicant advises that a significant amount of work has been carried out to assess the suitability of the North Kilbrannan Fish Farm by both Mowi and the statutory consultees. They suspect that these objectors have not reviewed or chosen to ignore the scientific-led assessments before repeating opinions which are beyond scientific-based facts. MOWI find this late stage intervention an attempt to lobby against the application very concerning. 3.0 ASSESSMENT This letter from the applicant does not raise any new material planning considerations over and above those set out, and fully assessed within the main report and supplementary report no.1. 4.0 RECOMMENDATION It is recommended that planning permission be approved subject to a pre-determination hearing and the revised conditions listed in Appendix 1 supplementary report no. 1. Author of Report: Sandra Davies Date: 22/5/23 Reviewing Officer: Peter Bain Date: 23/5/23 Fergus Murray Head of Development and Economic Growth