Supplementary Pack 1
Argyll and Bute Council · 30 March 2026
Back to Planning, Protective Services and Licensing Committee — 30 March 2026 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 Comhairle Earra-Ghàidheal Agus Bhòid Executive Director: Douglas Hendry Kilmory, Lochgilphead, PA31 8RT Tel: 01546 602127 Fax: 01546 604435 DX 599700 LOCHGILPHEAD 26 March 2026 SUPPLEMENTARY PACK 1 PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE - ON A HYBRID BASIS IN THE COUNCIL CHAMBER, KILMORY, LOCHGILPHEAD AND BY MICROSOFT TEAMS on MONDAY, 30 MARCH 2026 at 10:30 AM I enclose herewith supplementary reports for items 3 and 4 on the Agenda for the above meeting. Douglas Hendry Executive Director SUPPLEMENTARY REPORTS 3. MOWI SCOTLAND: REPLACE EXISTING 10 X 120M CIRCUMFERENCE PENS WITH 6 X 160M CIRCUMFERENCE PENS (WITH A PARALLEL MINOR RELOCATION INTO DEEPER WATER MOVING THE CARRADALE SOUTH SITE CENTRE 99M EAST) AND SITING OF EXISTING FEED BARGE IN A DIFFERENT LOCATION: CARRADALE SOUTH FISH FARM, KILBRANNAN SOUND (REF: 24/01381/MFF) (Pages 3 - 20) Report by Head of Development and Economic Growth 4. MOWI SCOTLAND: REPLACE EXISTING 10 X 120M CIRCUMFERENCE PENS WITH 6 X 160M CIRCUMFERENCE PENS (WITH A PARALLEL MINOR RELOCATION INTO DEEPER WATER MOVING THE CARRADALE NORTH SITE CENTRE 79M EAST) AND SITING OF EXISTING FEED BARGE IN A DIFFERENT LOCATION: CARRADALE NORTH FISH FARM, KILBRANNAN SOUND (REF: 24/01382/MFF) (Pages 21 - 38) Report by Head of Development and Economic Growth Planning, Protective Services and Licensing Committee Councillor John Armour Councillor Gordon Blair (Chair) Councillor Reeni Kennedy-Boyle Councillor Jan Brown Councillor Audrey Forrest Councillor Kieron Green (Vice-Chair) Public Document Pack
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Councillor Amanda Hampsey Councillor Daniel Hampsey Councillor Graham Hardie Councillor Fiona Howard Councillor Andrew Kain Councillor Paul Donald Kennedy Councillor Liz McCabe Councillor Dougie Philand Councillor Peter Wallace Contact: Fiona McCallum Tel. No. 01546 604392
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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: 24/01381/MFF Applicant: Mowi Scotland Proposal: Replace existing 10 x 120m circumference pens with 6 x 160m circumference pens (with a parallel minor relocation into deeper water moving the Carradale South site centre 99m east) and siting of existing feed barge in a different location Site Address: Carradale South Fish Farm, Kilbrannan Sound, Argyll and Bute SUPPLEMENTARY REPORT NO. 2 1. INTRODUCTION This application was presented to the Planning, Protective Services and Licensing (PPSL) Committee on 17th December 2025 with a supporting Report of Handling Committee Report detailing an officer recommendation to grant planning permission subject to planning conditions. Supplementary Report 1 was published on 16.12.2025 and detailed two further objections submitted by the Clyde Fishermen’s Association (CFA), the Applicant’s response to these objections (including review of available track data for vessels of interest) and provided updated wording of proposed Condition 18 in line with the requirements of the National Marine Plan. In addition, a late representation was received by Councillor Tommy MacPherson on 17.12.2025 and this was raised and addressed verbally by officers in the PPSL meeting. At the PPSL meeting, Councillor Andrew Kain moved to support the amendment, seconded by Councillor Paul Kennedy. A motion was also tabled by Councillor John Armour, seconded by Councillor Fiona Howard to agree to hold a site visit and a pre-determination hearing. A vote was taken by calling the roll, with the following outcome: Motion Amendment Councillor Armour Councillor Green Councillor A Hampsey Councillor Kain Councillor Hardie Councillor Kennedy Councillor Howard Councillor Philand Councillor Wallace The Motion was carried by 6 votes of 3 and the Committee resolved to hold a site visit and pre-determination hearing. Page 3 Agenda Item 3
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The purpose of this Supplementary Report 2 is to update elected members on details of further representations and further information submitted since the PPSL committee meeting, to identify where matters have been adequately dealt with in the Report of Handling Committee Report and Supplementary Report 1, to clarify where there are new matters and to detail any appropriate response to these matters on the part of the applicant. 2. ADDITIONAL REPRESENTATIONS Further representations received since 17.12.2025 are set out below. Please note full transcripts of all representations and consultation responses can be viewed on the Council’s public access website. Alex Gillies (email dated 16.12.2025 submitted via Members Zone uploaded 8.1.2026) - Objection: This is an area I have fished since I started fishing fifty-two years ago. It is right in the middle of tows we have that boats can tow from the south sound into the north sound if the weather turns bad and they can get fishing gear aboard safety. If this permission is granted this will not be possible. And by the way I employ eight men so this is very important to me. Bryan McDermid (letter dated 21.1.2026) – Neutral comment: I am a creel fisherman working in the local area and I have experience of these sites and operating alongside established fishing activity. I recognise that Mowi provides a number of stable jobs locally and contributes to various improvements within the village, including work at the harbour and Pier House. These contributions are appreciated within a rural community such as ours. I understand that the proposed upgrades require a small increase to the moorings area for the 160m pens. I can confirm that this would not affect my current fishing practices, and I have no objection to the proposed change. To my knowledge, no fishing vessels routinely operate within the area in question. From my perspective, the proposed modernisation does not present any conflict with my activities, and I therefore raise no objection to the applications. Tavish Scott, CEO, Salmon Scotland, 3rd Floor, Venue Studios, 21 Calton Road, Edinburgh EH8 8DL (letter dated 16.2.2026) - Support: As the trade body representing the Scottish farmed salmon sector, we recognise that the proposed development benefits both the local community and the wider supply chain across Scotland. Such developments in industry encourage business confidence and are essential to maintain innovation by enabling the modernisation of farm infrastructure, allowing producers to improve operational efficiency, environmental performance, and fish welfare practices. It’s disappointing to hear that the site has faced continuous opposition from local Fisheries stakeholders, despite repeated contact and engagement with local members, and associated representatives of Clyde Fisheries Association (CFA). MOWI engaged proactively with CFA from Pre-application, and with ongoing communication since the application was submitted in October 2024. They have submitted all necessary relevant assessments, presented reasonable mitigation strategies based on robust modelling predictions and monitoring, and made further efforts to engage and inform local dissatisfied stakeholders where these did not satisfy local boards, we firmly believe the site should be considered for approval by PPSL committee members. It is also worth noting that further efforts have been made at industry level to continue to facilitate and improve safe coexistence of aquaculture and local capture fisheries groups; Salmon Scotland, its producing members, members from Regional Inshore Fisheries Groups, and representatives from relevant Fisheries Associations from across areas of relevance (SFA, OFA, WIFA, CFA, CIFA, SFF) have all agreed to create a series of engagement liaisons, starting in 2026. These will focus on recognising the challenges faced by both sectors in regard to marine spatial squeeze, coexistence, and safety. The liaison series will aim to explore Page 4
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solutions as to how to create more streamlined engagement opportunities throughout the development and operations processes of a finfish farm. The Aquaculture and Fisheries Liaison Group is a co-developed steering group set up to encourage coexistence and foster good relations between the fishing and salmon farming across Scotland. Currently, the group’s objectives are to identify and discuss effectively on issues arising from the interaction of the fishing and salmon farming activities, and develop shared principles and best practice on engagement, and on data/information sharing. There is a separate workstream running under the same group and steered by the Scottish Fishing Safety Group and Salmon Scotland, aimed at revising instances of entanglement and updating current principles around navigation safety. Marine spatial squeeze and co-existence are not challenges unique to the salmon farming industry. Other industries in the Scottish marine economy sphere are facing similar challenges from fisheries, with increased occurrence in recent years. For example, the Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) was set up to foster good relations between the fishing and offshore renewable energy sectors and enable effective discussions on issues arising from the interaction of the fishing industry and offshore renewables activity as well as share and develop best practice. The existing site has been in successful operation for over 16 years, with all evidence provided in support of the application indicating there will be no significant adverse environmental impacts derived from the proposed changes to development. This position is further supported by representations from relevant statutory consultees, who have not objected to the proposed development. The proposal is part of modernisation programme seeking to enhance MOWIs responsible and sustainable approach to farming, by making demonstrable improvements to an existing farm, representative of the direction of travel undertaken by the wider salmon farming industry – a transition supported by the Scottish Government in their Vision for Sustainable Aquaculture. This change will support improvements in salmon farming practices, and in the sector’s sustainability credentials. Salmon farming companies and their employees contribute to the local economy through their spending with local shops, cafés, and other local businesses. MOWI has a track record of contributing towards thriving communities in Argyll & Bute. It has helped develop affordable housing on Colonsay, in partnership with local development companies, 6 new moorings for visiting yachts, and supplies to the local smokery at a preferential rate. More widely, farming companies have also delivered vital community infrastructure such as broadband, moorings, and slipway access. The salmon farming industry is an important socio-economic contributor to highland, rural, and island communities, therefore we fully support this application and the opportunity it represents for both local people and those employed in businesses across the wider supply chain. For all the reasons stated above, we fully support this application and the opportunity it represents for both local people and those employed in businesses across the wider supply chain. Aquasky Ltd (email from Stephen Barlow 4.3.2026) – neutral comment: We operate a small Argyll based business, Aquasky Ltd, offering underwater inspection and surveying services to marine sectors, including fish farming. From this we have acquired detailed and extensive knowledge of marine substrates in the vicinity of fish farms from underwater equipment-moorings inspections and environmental surveys, both of which have been undertaken at Carradale. Page 5
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I carried out the Environmental Impact Survey at Carradale for Mowi approximately 10 years ago. This compromised several transects running from the groups position offshore to a depth of approximately 120m.Then we followed a curved transect from the group's position out to flat level seabed at over 130m+ and back to the sites. The initial drop off from 50m down was very steep, with vertical drops of around 10 to 20m, this then became less steep until approaching the 100m depth where it again dropped steeply until around 140m where the seabed was flat mud / silt. Having worked on both a Prawn trawler and scallop dredger, and visually seen the ground worked as a diver, it is my opinion that a vessel, bottom trawling with nets, (prawn trawling) would not be able to operate shallower than 100m without incurring significant damage. Since the seabed is predominantly mud, scallop dredging would be uneconomical and also run the risk of the dredge bars either coming fast or capsizing. As can be seen from the attached chart the proposed extension does not extend beyond the 80m contour and thus does not impact any form of mobile bottom trawling. I have included screenshots of the actual moorings positions from a recent inspection, these have grid lines allowing scaling of any plots / areas required. East Kintyre Community Council (email from Jordan Becker 12.3.2026) – Support: East Kintyre Community Council wishes to express its support for the above planning applications submitted by Mowi relating to the upgrade of the existing fish farm installations at Carradale North and Carradale South. Aquaculture has long been an important part of the economy and working life of Carradale and the wider East Kintyre area. Mowi is a significant local employer and contributor to the community, and its continued presence supports local jobs, harbour activity, and the sustainability of the area as a working coastal community. Page 6
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The Community Council understands that the proposal represents a modernisation of existing infrastructure, replacing the current 10 x 120m circumference pens with 6 x 160m circumference pens at each site. We note that this change will not increase the permitted biomass or production levels, but instead introduces updated equipment designed to improve operational efficiency and enhance fish welfare and site management. We recognise that the small extension to the planning boundary required to accommodate the revised pen grid is limited and that the overall purpose of the application is to modernise existing sites in order to secure their long-term viability. East Kintyre Community Council welcomes continued investment in local aquaculture infrastructure and considers the proposed upgrades to be a positive and sensible development that will help safeguard existing operations and employment in the area. We also note the broader context of ongoing investment and interest in the future of Carradale harbour and associated local infrastructure. On this basis, East Kintyre Community Council supports planning applications 24/01382/MFF and 24/01381/MFF and encourages the planning authority to give them favourable consideration. 3. UPDATED COMMERCIAL FISHERIES REPORT Following the publication of Supplementary Report 1 and the sustained objections by the Clyde Fishermen’s Association, the applicant has submitted an updated Commercial Fisheries Report by Poseidon (February 2026) to address the issues raised and provide clarity on the findings of the previous Poseidon Commercial Fisheries report (October 2025) as summarised below. Data used and clarification of caveats The report uses datasets including bathymetry for depth contours both in and around the site and in this part of the Kilbrannan Sound, and analysis of substrate and habitat typology. This together indicates which types of vessels will likely use the areas around the site depending on depth ranges and type of fishing gear to be deployed e.g. trawls and dredges can only be used on level, reasonably smooth ground, whilst creels can be used in more complex rocky areas. The report uses UK Fisheries Landing Data from the iFish database (which shows landing into all ports by ICES rectangle, EEZ of capture, quota stock and port of landing (2019 - 2023)) and Scottish Sea Fisheries Statistics – issued in 2024 and updated March 2025, shows the tonnage and value of all landings of sea fish and shellfish by Scottish vessels, all landings into Scotland, the rest of the UK and abroad. Historical Automatic Identification System (AIS) data is also used to show the almost real-time (every 5 minutes) position and movement of the 20 identified fishing vessels equipped with AIS transmitters operating within the area. It is required by all vessels >15 m in length but can also be used by smaller vessels. This data is supported by spatial data layers of fishing intensity/pressure which are derived from mandatory vessel monitoring system (VMS) data that includes all fishing vessels 12 m and larger, as required by the Maritime Marine Office (MMO) and provides coarse (about 15 km² blocks) spatial information on fishing intensity by gear type. The report acknowledges there are data gaps such as the spatial distribution and effort of the fishing vessels. Whilst this is well captured for the larger vessels that are included in the AIS and VMS surveillance systems, this is not necessarily so for the smaller vessels, e.g. <12 m in length. However, the MMO vessel lists suggest that of the 76 vessels with Ayr, Page 7
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Campbeltown, Tarbert and Troon & Saltcoats as home ports, the majority (49 vessels, 64%) are 12 m) vessels in this area, and therefore, the geographic footprint and overlap with the farm is well represented in the Poseidon report. The Poseidon Report does not attempt to measure the socio economic impact of the farm’s boundary changes on wild capture fisheries interests, especially of the more numerous smaller vessels. However, based on the fact that mobile fishing vessels (e.g. bottom trawlers fishing for Nephrops and to a lesser extent dredgers fishing for scallops) of all sizes fishing the inshore waters of the Kilbrannan Sound are likely to fish the same muddy habitat to the east of the site - historic fishing patterns suggests that there is very little fishing by mobile fishing vessels of any size within the proposed boundary area. Nephrops creeling takes place in the deeper, muddier sediments to the north and south of the pens. It is possible that some creeling takes place within the extended proposed planning area but given that it is sandwiched between the farm moorings to the west and the mobile gear fishing zone to the east, this is unlikely. Review of ‘land farm’ comparison as raised by the Clyde Fishermen’s Association The land farm analogy is flawed as it is based upon the premise that of the 40 acres total farm size, only 2 acres (5%) are productive, with the remaining 38 acres (95%) that “cannot be worked”. In the case of the Carradale north and south marine fish farms, around 65% of the Kilbrannan Sound sea area to the east of the fish farm is being regularly fished and can be considered as ‘safe and productive’, compared to the zero percent in the land analogy. Only 1.35% of the fishing vessel positions recorded were in the extended boundary area. Whilst we recognise the sensitivity of cumulative spatial squeeze being faced by the fishing industry, we maintain that this is to be a minor relocation for the mobile fishing fleet. Please also refer to Figures 1, 2, 3 and 4 reproduced in Appendix A of this Supplementary Report. Value chain analysis The intention of this report is to comment on the impact of the boundary change rather than to conduct a full value chain analysis (VCA). Firstly, we do not dispute the importance of including the full value chain when determining the socio-economic contribution of wild fisheries and we accept the results of Seafish’s economic assessment referred to by CFA noting the variability in these calculated figures depending upon fleet segment and calculation methodology. The key question is what is the impact of the proposed boundary change on fishing activity and whether this results in an actual loss of fishing opportunity and resultant socio-economic contribution? From the results of the initial Poseidon Report and the additional work done to assess relative levels of activity (i) in the extended boundary zone and (ii) the wider Kilbrannan Sound, the boundary change would result in little actual loss. In particular, we would have the following observations: • Of the 1,034 position readings recorded in this segment of the Kilbrannan Sound over a 5 year period, only 14 (1.35%) were located within the extended boundary area. • Furthermore, the majority of these were in the south-east corner of the southern farm site outside the truncated part of the planning boundary and would be unaffected by the boundary extension. • This suggests that there is very little dependency (based on the last five years’ activity of AIS equipped vessels) on the area affected by the boundary extension. • Furthermore, if the boundary extension were granted, the small number of vessels affected are unlikely to stop fishing and would instead be displaced to the east where the majority of the mobile gear fishing already takes place. Given the limited AIS records in the extension zone observed, the level of displacement would both be low and easily absorbed. In our view, the boundary extension would result in a Page 8
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narrower buffer zone between the farm and the main distribution of fishing activity than currently exists. This would need to be mitigated through: (i) the precise positioning of the farm’s new anchor legs and (ii) robust marking and lighting of the farm and its surface and sub-sea infrastructure. Officer comment: these mitigations are captured through planning conditions and are standard to marine fish farm proposals. The full Poseidon Commercial Fisheries Report is available on public access. 4. APPLICANT RESPONSE TO COUNCILLOR MACPHERSON A response was provided by the applicant in relation to the queries raised in the late representation by Cllr MacPherson on 17.12.2025. While the procedural planning matters raised were addressed at the PPSL meeting by the case officer, this response clarifies the status of the planning application in the planning hierarchy and confirms that no reference to the ‘Carradale Fishermen’s Association’ has been made by the Applicant in relation to this application. The response also sets out that vessels using both mobile and static fishing gear have been included in the Poseidon Commercial Fisheries Report as far as possible given available information and notes that the vessels listed by Mr Gillies and Cllr MacPherson (Jeniska cn153 and the Rebekah Jayne OB235) have both been included in the analysis provided within the Commercial Fisheries Report. With regards to representations by local fishermen, the applicant confirms the following vessels have also been included within the analysis: • MFV Atlas CN258 – A. Hamilton (MFV ATLAS (IMO 8535611) • MFV Radiant Morn – James Anderson (RADIANT MORN (MMSI 235004039). • MFV Jeniska (CN153) (JENISKA (MMSI 235085294) • MFV Rebekah Jayne (OB235) (REBEKAH.JAYNE (MMSI 232003730) MFV Atlas (CN258), MFV Radiant Morn and MFV Rebekah Jayne (OB235) (REBEKAH.JAYNE (MMSI 232003730) all have a recorded overall length of 16m. MFV Jeniska (CN153) has a recorded length of 22m. Since these vessels are required to track their position, Mowi can confirm that each have been considered within the Poseidon fisheries report, where no significant displacement effects could be seen within the proposed moorings area, considering fishing vessel tracks for the last 5 years. The response also confirms that no tracked vessels were excluded from the analysis, and as such all Northern Irish fishing vessels >12m in length have been represented, if present. All vessels >12m are included in Poseidon’s fisheries analysis, regardless of fishing gear type. Vessels <12m could not be captured using this approach, however it is understood that the majority of trawlers will be >12m. To address the identified gap in information for smaller vessels, Mowi have approached a number of local prawn fishermen in the Carradale vicinity since the planning meeting in December 2025, who have contributed to maps, annotating charts with the grounds that they typically utilise (please see Appendix B). These have been identified as the areas to the north and south of the existing and proposed sites, as well as the deeper channel to the east of the proposal and shallower area west of the Isle of Arran. The identities of the four vessels represented have been redacted for data protection but can be provided on request. A further fishing heatmap for >12m vessels has also been provided in the supplementary report prepared by Poseidon and submitted to Argyll & Bute Council in February 2026. This confirms that there remains no significant displacement predicted as a result of the proposed changes, considering all available information. Page 9
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Officer comment: these matters provide further reassurance that the impact on commercial fisheries has been fully considered and that any displacement of vessels is not significant given the extent of fishing grounds in the Kilbrannan Sound. All other matters have already been suitably addressed in the Report of Handling and the Committee Report and do not result in a change to the officer recommendation. The full Applicant response to Cllr Tommy Macpherson is available on public access. 5. FURTHER MINOR REVISIONS TO CONDITION 18 Further minor revisions are proposed to planning condition 18 to ensure all local fishing vessels are included in ongoing liaison and on any confusion about the types of vessels that will be facilitated access. 18. Local Fisheries Liaison Within three months of the date of this decision the applicant shall establish a forum for effective operational communication with local fishing vessels, including members of the Clyde Fisheries Association and if deemed necessary, agree a Fisheries Management and Mitigation Strategy. This forum shall be used to agree and implement proposed operational mitigation mechanisms in relation to sharing of installed mooring anchor coordinates and the provision of enhanced navigational lighting and anchor markers where possible. Reason: In order to support co-existence of local fisheries and salmon farming on this site and ensure both navigational and fish pen containment safety while maintaining as much access to fishing grounds for creeling and other fishing vessels as is reasonably practicable in line with the provisions of LDP2, NPF4 and The National Marine Plan. 6. POLICY ASSESSMENT The representations and further submissions received since the December PPSL meeting do not raise any new material planning considerations over and above those fully assessed within the previous Report of Handling/Committee Report and Supplementary Report 1. The further clarifications on data used in the previously submitted Commercial Fisheries Report are useful and the additional analysis of the impact of the proposal on commercial fisheries provides reassurance that the localised commercial fisheries impact will be minimal in the context of the wider fishing grounds available in the Kilbrannan Sound. It is noted that there has been ongoing dialogue between the applicant and the main objecting party, the CFA who represent local fisheries, throughout the planning process. In response to these ongoing discussions, the proposal’s moorings have been redesigned to reduce the impact of the proposal on local fishing grounds. The applicant has also committed to facilitate safe access to grounds near to the proposed boundaries for those smaller vessels using mobile fishing gear and a number of mitigation measures - including sharing of the anchor co- ordinates and safety buoy lighting are proposed to be implemented through planning conditions. Furthermore, Condition 18 is intended to ensure that the mitigation offered by Mowi to the local fishing boats is effectively secured and that communication continues to facilitate safe co-existence of aquaculture and local fisheries. Condition 18 includes provisions for a Fisheries Management and Mitigation Strategy if deemed necessary, to address the requirements of the National Marine Plan in instances where existing fishing opportunities or activity cannot be fully safeguarded. It is noted that strategies such as this are usually reserved for much larger and new marine developments. Page 10
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As such, the proposal fully complies with Argyll and Bute Local Development Plan 2 Policy 28 - Supporting Sustainable Aquatic and Coastal Development and other relevant LDP2 policies. The proposal is considered to comply with the provisions of the National Planning Framework 4 Policy 32 – Aquaculture and is also in compliance with the relevant provisions of the National Marine Plan – specifically policies FISHERIES 2 and FISHERIES 3 of Chapter 6: Sea Fisheries. There is an existing operational fish farm in this location and the proposal represents a minor relocation of the site centre 99m to the east. The proposals are part of a wider modernisation plan that is beneficial in terms of fish health, operational efficiencies and health and safety of site workers, and which supports a key local employer and local, regional and national economic contributor. Therefore, officers consider there are insufficient grounds to recommend refusing the application. 7.0 RECOMMENDATION It is recommended that planning permission be approved subject to a pre-determination hearing, the planning conditions listed in Appendix C of this Supplementary Report 2. (including revised condition 18 ). Author of Report: Shelley Gould Date: 26.3.2026 Reviewing Officer: Sandra Davies Date: 26.3.2026 Fergus Murray Head of Development and Economic Growth Page 11
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Appendix A: Further commercial fisheries impact analysis of the proposed boundary changes. Page 12
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Appendix B: Further direct consultation undertaken by applicant with local fishermen of vessels <12m (hand annotated maps) Page 14
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APPENDIX C CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 24/01381/MFF Standard Time Limit Condition (as defined by Regulation) Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 3.7.2024, supporting information and, the approved drawings listed in the table below unless the prior written approval of the Planning Authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received General view and location of Carradale fish farm site location Annex 1: Figure 1 0001 16.9.2025 Existing site location (installed) (1:8,000) (dated 4.10.2024) Annex 1 16.9.2025 Existing (installed) & Proposed site (1:8,000) (dated 24.3.2025) Annex 1 16.9.2025 Proposed site (1:8,000) (dated 24.3.2025) Annex 1 16.9.2025 Admiralty Chart Proposed site (1:25,000) (dated 24.3.2025) Annex 1 16.9.2025 Proposed equipment co-ordinates Annex 1 16.9.2025 Existing equipment co-ordinates Annex 1 16.9.2025 Existing elevations – configuration 120m pens in 75m matrix grid (dated 11.7.2022) Annex 2: Figure 1 0001 31.7.2024 Proposed elevations - configuration 160m pens in 100m matrix grid (dated: 2.4.2020) Annex 2: Figure 2 10.10.2024 Manufacturers Diagram - Typical Moorings Design (dated 2.4.2020) Annex 2: Figure 5 0001 31.7.2024 Manufacturers Diagram – Net Design (dated 2.4.2020) Annex 2: Figure 3 0001 31.7.2024 Manufacturers Diagram – Top Net Support Structure (dated 7.5.2021) Annex 2: Figure 4 0001 31.7.2024 Manufacturers Design Specification – 160m pen (dated 17.6.2021) Annex 11 14.10.2024 Existing feed barge photographs (dated October 2024) Annex 10 14.10.2024 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. Acoustic Deterrent Devices No Acoustic Deterrent Devices (ADDs) shall be deployed at the site hereby approved. Page 16
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Reason: In the interests of nature conservation. This planning application has been assessed on the basis that ADDs will not be used. The use of ADDs would be regarded as a material change to the proposal. 3. Biomass and Stocking The development hereby approved shall not be operated other than with a biomass of 2500 tonnes or less and shall only stock one species of fin fish (other than cleaner fish). Reason: The environmental effects of this proposal have been assessed against this maximum biomass of one species. 4. Fallow Period There shall be a minimum of 28 days in each calendar year when the site will be fallow and this shall be applied synchronously with the other fish farms within the Kilbrannan Sound FMA. Reason: In the interests of nature conservation. 5 Removal of Existing Equipment Prior to the development hereby approved being brought into use, the redundant equipment relating to the previous layout shall be removed from the site. In the event that the development or any associated equipment approved by this permission ceases to be in operational use for a period exceeding three years, the equipment shall be wholly removed from the site thereafter, unless otherwise agreed in writing by the Planning Authority. Reason: In the interest of visual amenity and to accord with LDP2 Policy 29. 6. Redundant Equipment/Equipment Failure In the event of equipment falling into disrepair or becoming damaged, adrift, stranded, abandoned or sunk in such a manner as to cause an obstruction or danger to navigation, the developer shall carry out or make suitable arrangements for the carrying out of all measures necessary for lighting, buoying, raising, repairing, moving or destroying, as appropriate, the whole or any part of the equipment. Reason: In the interest of visual amenity and safe navigation. 7. Finished Surfaces The finished surfaces of all equipment above the water surface, excluding the feed barge, but inclusive of the surface floats and buoys associated with the development hereby permitted (excluding those required to comply with navigational requirements) shall be non-reflective and finished in a dark recessive colour unless otherwise agreed in advance in writing by the planning authority. Reason: In the interest of visual amenity. 8. Lighting Page 17
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All lighting above the water surface and not required for safe navigation purposes should be directed downwards by shielding and be extinguished when not required for the purpose for which it is installed on the site. Reason: In the interest of visual amenity and navigational safety. 9. Noise The Noise Rating Level attributable to the operational activities associated with the approved fish farm shall not exceed background noise levels by more than 3dB(A) at any noise sensitive property measured and assessed in accordance with BS4142:2014. Reason: In order to protect the amenities of the area from noise nuisance. 10. Proactive notification of fish movement operations The applicant shall provide the dates of any planned fish movements utilising large vessels in a year in advance in writing to the Planning Authority. Reason: In the interests of improving monitoring and reducing impacts on amenity. 11. Hours of operation Except where the planning authority has been notified under the provisions of condition 10 or in situations outwith the applicant’s control (e.g. tidal conditions, fish movements delayed by bad weather or fish health interventions); no operations, other than water pumping, feeding, servicing, environmental monitoring and maintenance testing of plant/equipment shall take place on site outwith the following times: 07.00 hours to 20.00 hours over 7 days. Reason: In the interests of amenity. 12. Mitigating impacts of operations (including out of hours and Well Boat operations) All site operations including: • the use of equipment integral to the production cycle (e.g. underwater lighting and aeration systems or well boats) which is required to run overnight for fish health reasons; • operations notified under the provisions of condition 10; and • any fish health interventions or delayed operations out of hours, shall adhere to the best practice measures detailed in the ‘Further Supporting Information - mitigation of amenity impacts arising from operational effects’ document (submitted by MOWI on 12.9.2025). All delayed or out of hours operations required to be undertaken outwith the provisions of condition 10 shall be recorded by the applicant. A record of these out of hours activities shall then be made available to the Planning Authority on request. Reason: In the interests of improving monitoring and reducing impacts on amenity. 13. Environmental Management Plan (EMP) Page 18
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The development site shall be operated in accordance with the submitted Environmental Management Plan (Kilbrannan Sound EMP (8.2.24). The EMP should be reviewed and updated if required following the adoption by Scottish Government of any new policy framework relevant to sea lice management and wild salmonid interactions. Any proposed amendments to the EMP shall be submitted to and approved in writing by the planning authority prior to the changes being implemented. Reason: In the interests of nature conservation and protecting the environment. 14. Waste Management Plan The development shall be carried out in accordance with the Carradale Waste Management Plan dated July 2024 or as updated and agreed in writing with the Planning Authority. Reason: To ensure that waste is dealt with in a sustainable manner in accordance with Development Plan policy. 15. Containment and Contingency Escapes Plan The development shall be carried out in accordance with the Containment and Contingency Escapes Plan dated April 2024 or as updated and agreed in writing with the Planning Authority. Reason: to maintain the integrity of the holding structures and the measures to be taken in the event of a suspected escape. The plan is specific to the proposed installation of 160 m circumference pens. 16. Sea Lice Policy Strategy and Efficacy Statement The development shall be carried out in accordance with the ‘Carradale Sea Lice – Policy, Strategy and Efficacy Statement’ dated October 2024 or as updated and agreed in writing with the Planning Authority. Reason: In the interests of nature conservation. 17. Biodiversity Enhancement Proposals Within 3 months of the date on this planning permission, a Biodiversity Enhancement Strategy shall be submitted for the approval of the planning authority. Thereafter the applicant shall implement the proposals in line with the approved strategy and provide updates at the request of the planning authority. Reason: In order to protect biodiversity, reverse biodiversity loss, deliver positive biodiversity effects and strengthen nature networks in accordance with the requirements of NPF 4 Policy 3. 18. Local Fisheries Liaison Within three months of the date of this decision the applicant shall establish a forum for effective operational communication with local fishing vessels, including members of the Clyde Fisheries Association and if deemed necessary, agree a Fisheries Management and Mitigation Strategy. This forum shall be used to agree and implement proposed operational mitigation mechanisms in relation to sharing of Page 19
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installed mooring anchor coordinates and the provision of enhanced navigational lighting and anchor markers where possible. Reason: In order to support co-existence of local fisheries and salmon farming on this site and ensure both navigational and fish pen containment safety while maintaining as much access to grounds for fishing vessels as is reasonably practicable in line with the provisions of LDP2, NPF4 and The National Marine Plan. Page 20
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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: 24/01382/MFF Applicant: Mowi Scotland Proposal: Replace existing 10 x 120m circumference pens with 6 x 160m circumference pens (with a parallel minor relocation into deeper water moving the Carradale South site centre 79m east) and siting of existing feed barge in a different location Site Address: Carradale North Fish Farm, Kilbrannan Sound, Argyll and Bute SUPPLEMENTARY REPORT NO. 2 1. INTRODUCTION This application was presented to the Planning, Protective Services and Licensing (PPSL) Committee on 17th December 2025 with a supporting Report of Handling Committee Report detailing an officer recommendation to grant planning permission subject to planning conditions. Supplementary Report 1 was published on 16.12.2025 and detailed two further objections submitted by the Clyde Fishermen’s Association (CFA), the Applicant’s response to these objections (including review of available track data for vessels of interest) and provided updated wording of proposed Condition 18 in line with the requirements of the National Marine Plan. In addition, a late representation was received by Councillor Tommy MacPherson on 17.12.2025 and this was raised and addressed verbally by officers in the PPSL meeting. At the PPSL meeting, Councillor Andrew Kain moved to support the amendment, seconded by Councillor Paul Kennedy. A motion was also tabled by Councillor John Armour, seconded by Councillor Fiona Howard to agree to hold a site visit and a pre-determination hearing. A vote was taken by calling the roll, with the following outcome: Motion Amendment Councillor Armour Councillor Green Councillor A Hampsey Councillor Kain Councillor Hardie Councillor Kennedy Councillor Howard Councillor Philand Councillor Wallace The Motion was carried by 6 votes of 3 and the Committee resolved to hold a site visit and pre-determination hearing. Page 21 Agenda Item 4
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The purpose of this Supplementary Report 2 is to update elected members on details of further representations and further information submitted since the PPSL meeting, to identify where matters have been adequately dealt with in the Report of Handling Committee Report and Supplementary Report 1, to clarify where there are new matters and to detail any appropriate response to these matters on the part of the applicant. 2. ADDITIONAL REPRESENTATIONS Further representations received since 17.12.2025 are set out below. Please note full transcripts of all representations and consultation responses can be viewed on the Council’s public access website. Bryan McDermid (letter dated 21.1.2026) – Neutral comment: I am a creel fisherman working in the local area and I have experience of these sites and operating alongside established fishing activity. I recognise that Mowi provides a number of stable jobs locally and contributes to various improvements within the village, including work at the harbour and Pier House. These contributions are appreciated within a rural community such as ours. I understand that the proposed upgrades require a small increase to the moorings area for the 160m pens. I can confirm that this would not affect my current fishing practices, and I have no objection to the proposed change. To my knowledge, no fishing vessels routinely operate within the area in question. From my perspective, the proposed modernisation does not present any conflict with my activities, and I therefore raise no objection to the applications. Alex Gillies (email dated 16.12.2025 submitted via Members Zone uploaded 8.1.2026) - Objection: This is an area I have fished since I started fishing fifty-two years ago. It is right in the middle of tows we have that boats can tow from the south sound into the north sound if the weather turns bad and they can get fishing gear aboard safety. If this permission is granted this will not be possible. And by the way I employ eight men so this is very important to me. Tavish Scott, CEO, Salmon Scotland, 3rd Floor, Venue Studios, 21 Calton Road, Edinburgh EH8 8DL (letter dated 16.2.2026) - Support: As the trade body representing the Scottish farmed salmon sector, we recognise that the proposed development benefits both the local community and the wider supply chain across Scotland. Such developments in industry encourage business confidence and are essential to maintain innovation by enabling the modernisation of farm infrastructure, allowing producers to improve operational efficiency, environmental performance, and fish welfare practices. It’s disappointing to hear that the site has faced continuous opposition from local Fisheries stakeholders, despite repeated contact and engagement with local members, and associated representatives of Clyde Fisheries Association (CFA). MOWI engaged proactively with CFA from Pre-application, and with ongoing communication since the application was submitted in October 2024. They have submitted all necessary relevant assessments, presented reasonable mitigation strategies based on robust modelling predictions and monitoring, and made further efforts to engage and inform local dissatisfied stakeholders where these did not satisfy local boards, we firmly believe the site should be considered for approval by PPSL committee members. It is also worth noting that further efforts have been made at industry level to continue to facilitate and improve safe coexistence of aquaculture and local capture fisheries groups; Salmon Scotland, its producing members, members from Regional Inshore Fisheries Groups, and representatives from relevant Fisheries Associations from across areas of relevance (SFA, OFA, WIFA, CFA, CIFA, SFF) have all agreed to create a series of engagement liaisons, starting in 2026. These will focus on recognising the challenges faced by both sectors in regard to marine spatial squeeze, coexistence, and safety. The liaison series will aim to explore Page 22
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solutions as to how to create more streamlined engagement opportunities throughout the development and operations processes of a finfish farm. The Aquaculture and Fisheries Liaison Group is a co-developed steering group set up to encourage coexistence and foster good relations between the fishing and salmon farming across Scotland. Currently, the group’s objectives are to identify and discuss effectively on issues arising from the interaction of the fishing and salmon farming activities, and develop shared principles and best practice on engagement, and on data/information sharing. There is a separate workstream running under the same group and steered by the Scottish Fishing Safety Group and Salmon Scotland, aimed at revising instances of entanglement and updating current principles around navigation safety. Marine spatial squeeze and co-existence are not challenges unique to the salmon farming industry. Other industries in the Scottish marine economy sphere are facing similar challenges from fisheries, with increased occurrence in recent years. For example, the Fishing Liaison with Offshore Wind and Wet Renewables Group (FLOWW) was set up to foster good relations between the fishing and offshore renewable energy sectors and enable effective discussions on issues arising from the interaction of the fishing industry and offshore renewables activity as well as share and develop best practice. The existing site has been in successful operation for over 16 years, with all evidence provided in support of the application indicating there will be no significant adverse environmental impacts derived from the proposed changes to development. This position is further supported by representations from relevant statutory consultees, who have not objected to the proposed development. The proposal is part of modernisation programme seeking to enhance MOWIs responsible and sustainable approach to farming, by making demonstrable improvements to an existing farm, representative of the direction of travel undertaken by the wider salmon farming industry – a transition supported by the Scottish Government in their Vision for Sustainable Aquaculture. This change will support improvements in salmon farming practices, and in the sector’s sustainability credentials. Salmon farming companies and their employees contribute to the local economy through their spending with local shops, cafés, and other local businesses. MOWI has a track record of contributing towards thriving communities in Argyll & Bute. It has helped develop affordable housing on Colonsay, in partnership with local development companies, 6 new moorings for visiting yachts, and supplies to the local smokery at a preferential rate. More widely, farming companies have also delivered vital community infrastructure such as broadband, moorings, and slipway access. The salmon farming industry is an important socio-economic contributor to highland, rural, and island communities, therefore we fully support this application and the opportunity it represents for both local people and those employed in businesses across the wider supply chain. For all the reasons stated above, we fully support this application and the opportunity it represents for both local people and those employed in businesses across the wider supply chain. Aquasky Ltd (email from Stephen Barlow 4.3.2026) – neutral comment: We operate a small Argyll based business, Aquasky Ltd, offering underwater inspection and surveying services to marine sectors, including fish farming. From this we have acquired detailed and extensive knowledge of marine substrates in the vicinity of fish farms from underwater equipment-moorings inspections and environmental surveys, both of which have been undertaken at Carradale. Page 23
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I carried out the Environmental Impact Survey at Carradale for Mowi approximately 10 years ago. This compromised several transects running from the groups position offshore to a depth of approximately 120m.Then we followed a curved transect from the group's position out to flat level seabed at over 130m+ and back to the sites. The initial drop off from 50m down was very steep, with vertical drops of around 10 to 20m, this then became less steep until approaching the 100m depth where it again dropped steeply until around 140m where the seabed was flat mud / silt. Having worked on both a Prawn trawler and scallop dredger, and visually seen the ground worked as a diver, it is my opinion that a vessel, bottom trawling with nets, (prawn trawling) would not be able to operate shallower than 100m without incurring significant damage. Since the seabed is predominantly mud, scallop dredging would be uneconomical and also run the risk of the dredge bars either coming fast or capsizing. As can be seen from the attached chart the proposed extension does not extend beyond the 80m contour and thus does not impact any form of mobile bottom trawling. I have included below screenshots of the actual moorings positions from a recent inspection, these have grid lines allowing scaling of any plots / areas required. East Kintyre Community Council (email from Jordan Becker 12.3.2026) – Support: East Kintyre Community Council wishes to express its support for the above planning applications submitted by Mowi relating to the upgrade of the existing fish farm installations at Carradale North and Carradale South. Aquaculture has long been an important part of the economy and working life of Carradale and the wider East Kintyre area. Mowi is a significant local employer and contributor to the community, and its continued presence supports local jobs, harbour activity, and the sustainability of the area as a working coastal community. Page 24
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The Community Council understands that the proposal represents a modernisation of existing infrastructure, replacing the current 10 x 120m circumference pens with 6 x 160m circumference pens at each site. We note that this change will not increase the permitted biomass or production levels, but instead introduces updated equipment designed to improve operational efficiency and enhance fish welfare and site management. We recognise that the small extension to the planning boundary required to accommodate the revised pen grid is limited and that the overall purpose of the application is to modernise existing sites in order to secure their long-term viability. East Kintyre Community Council welcomes continued investment in local aquaculture infrastructure and considers the proposed upgrades to be a positive and sensible development that will help safeguard existing operations and employment in the area. We also note the broader context of ongoing investment and interest in the future of Carradale harbour and associated local infrastructure. On this basis, East Kintyre Community Council supports planning applications 24/01382/MFF and 24/01381/MFF and encourages the planning authority to give them favourable consideration. 3. UPDATED COMMERCIAL FISHERIES REPORT Following the publication of Supplementary Report 1 and the sustained objections by the Clyde Fishermen’s Association, the applicant has submitted an updated Commercial Fisheries Report by Poseidon (February 2026) to address the issues raised and provide clarity on the findings of the previous Poseidon Commercial Fisheries report (October 2025) as summarised below. Data used and clarification of caveats The report uses datasets including bathymetry for depth contours both in and around the site and in this part of the Kilbrannan Sound, and analysis of substrate and habitat typology. This together indicates which types of vessels will likely use the areas around the site depending on depth ranges and type of fishing gear to be deployed e.g. trawls and dredges can only be used on level, reasonably smooth ground, whilst creels can be used in more complex rocky areas. The report uses UK Fisheries Landing Data from the iFish database (which shows landing into all ports by ICES rectangle, EEZ of capture, quota stock and port of landing (2019 - 2023)) and Scottish Sea Fisheries Statistics – issued in 2024 and updated March 2025, shows the tonnage and value of all landings of sea fish and shellfish by Scottish vessels, all landings into Scotland, the rest of the UK and abroad. Historical Automatic Identification System (AIS) data is also used to show the almost real-time (every 5 minutes) position and movement of the 20 identified fishing vessels equipped with AIS transmitters operating within the area. It is required by all vessels >15 m in length but can also be used by smaller vessels. This data is supported by spatial data layers of fishing intensity/pressure which are derived from mandatory vessel monitoring system (VMS) data that includes all fishing vessels 12 m and larger, as required by the Maritime Marine Office (MMO) and provides coarse (about 15 km² blocks) spatial information on fishing intensity by gear type. The report acknowledges there are data gaps such as the spatial distribution and effort of the fishing vessels. Whilst this is well captured for the larger vessels that are included in the AIS and VMS surveillance systems, this is not necessarily so for the smaller vessels, e.g. <12 m in length. However, the MMO vessel lists suggest that of the 76 vessels with Ayr, Page 25
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Campbeltown, Tarbert and Troon & Saltcoats as home ports, the majority (49 vessels, 64%) are 12 m) vessels in this area, and therefore, the geographic footprint and overlap with the farm is well represented in the Poseidon report. The Poseidon Report does not attempt to measure the socio economic impact of the farm’s boundary changes on wild capture fisheries interests, especially of the more numerous smaller vessels. However, based on the fact that mobile fishing vessels (e.g. bottom trawlers fishing for Nephrops and to a lesser extent dredgers fishing for scallops) of all sizes fishing the inshore waters of the Kilbrannan Sound are likely to fish the same muddy habitat to the east of the site - historic fishing patterns suggests that there is very little fishing by mobile fishing vessels of any size within the proposed boundary area. Nephrops creeling takes place in the deeper, muddier sediments to the north and south of the pens. It is possible that some creeling takes place within the extended proposed planning area but given that it is sandwiched between the farm moorings to the west and the mobile gear fishing zone to the east, this is unlikely. Review of ‘land farm’ comparison as raised by the Clyde Fishermen’s Association The land farm analogy is flawed as it is based upon the premise that of the 40 acres total farm size, only 2 acres (5%) are productive, with the remaining 38 acres (95%) that “cannot be worked”. In the case of the Carradale north and south marine fish farms, around 65% of the Kilbrannan Sound sea area to the east of the fish farm is being regularly fished and can be considered as ‘safe and productive’, compared to the zero percent in the land analogy. Only 1.35% of the fishing vessel positions recorded were in the extended boundary area. Whilst we recognise the sensitivity of cumulative spatial squeeze being faced by the fishing industry, we maintain that this is to be a minor relocation for the mobile fishing fleet. Please also refer to Figures 1, 2, 3 and 4 reproduced in Appendix A of this Supplementary Report. Value chain analysis The intention of this report is to comment on the impact of the boundary change rather than to conduct a full value chain analysis (VCA). Firstly, we do not dispute the importance of including the full value chain when determining the socio-economic contribution of wild fisheries and we accept the results of Seafish’s economic assessment referred to by CFA noting the variability in these calculated figures depending upon fleet segment and calculation methodology. The key question is what is the impact of the proposed boundary change on fishing activity and whether this results in an actual loss of fishing opportunity and resultant socio-economic contribution? From the results of the initial Poseidon Report and the additional work done to assess relative levels of activity (i) in the extended boundary zone and (ii) the wider Kilbrannan Sound, the boundary change would result in little actual loss. In particular, we would have the following observations: • Of the 1,034 position readings recorded in this segment of the Kilbrannan Sound over a 5 year period, only 14 (1.35%) were located within the extended boundary area. • Furthermore, the majority of these were in the south-east corner of the southern farm site outside the truncated part of the planning boundary and would be unaffected by the boundary extension. • This suggests that there is very little dependency (based on the last five years’ activity of AIS equipped vessels) on the area affected by the boundary extension. • Furthermore, if the boundary extension were granted, the small number of vessels affected are unlikely to stop fishing and would instead be displaced to the east where the majority of the mobile gear fishing already takes place. Given the limited AIS records in the extension zone observed, the level of displacement would both be low and easily absorbed. In our view, the boundary extension would result in: Page 26
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• A narrower buffer zone between the farm and the main distribution of fishing activity than currently exists. This would need to be mitigated through (i) the precise positioning of the farm’s new anchor legs and (ii) robust marking and lighting of the farm and its surface and sub-sea infrastructure. Officer comment: these mitigations are captured through planning conditions and are standard to marine fish farm proposals. The full Poseidon Commercial Fisheries Report is available on public access. 4. APPLICANT RESPONSE TO COUNCILLOR MACPHERSON A response was provided by the applicant in relation to the queries raised in the late representation by Cllr MacPherson on 17.12.2025. While the procedural planning matters raised were addressed at the PPSL meeting by the case officer, this response clarifies the status of the planning application in the planning hierarchy and confirms that no reference to the ‘Carradale Fishermen’s Association’ has been made by the Applicant in relation to this application. The response also sets out that vessels using both mobile and static fishing gear have been included in the Poseidon Commercial Fisheries Report as far as possible given available information and notes that the vessels listed by Mr Gillies and Cllr MacPherson (Jeniska cn153 and the Rebekah Jayne OB235) have both been included in the analysis provided within the Commercial Fisheries Report. With regards to representations by local fishermen, the applicant confirms the following vessels have also been included within the analysis: • MFV Atlas CN258 – A. Hamilton (MFV ATLAS (IMO 8535611) • MFV Radiant Morn – James Anderson (RADIANT MORN (MMSI 235004039). • MFV Jeniska (CN153) (JENISKA (MMSI 235085294) • MFV Rebekah Jayne (OB235) (REBEKAH.JAYNE (MMSI 232003730) MFV Atlas (CN258), MFV Radiant Morn and MFV Rebekah Jayne (OB235) (REBEKAH.JAYNE (MMSI 232003730) all have a recorded overall length of 16m. MFV Jeniska (CN153) has a recorded length of 22m. Since these vessels are required to track their position, Mowi can confirm that each have been considered within the Poseidon fisheries report, where no significant displacement effects could be seen within the proposed moorings area, considering fishing vessel tracks for the last 5 years. The response also confirms that no tracked vessels were excluded from the analysis, and as such all Northern Irish fishing vessels >12m in length have been represented, if present. All vessels >12m are included in Poseidon’s fisheries analysis, regardless of fishing gear type. Vessels <12m could not be captured using this approach, however it is understood that the majority of trawlers will be >12m. To address the identified gap in information for smaller vessels, Mowi have approached a number of local prawn fishermen in the Carradale vicinity since the planning meeting in December 2025, who have contributed to maps, annotating charts with the grounds that they typically utilise (please see Appendix B). These have been identified as the areas to the north and south of the existing and proposed sites, as well as the deeper channel to the east of the proposal and shallower area west of the Isle of Arran. The identities of the four vessels represented have been redacted for data protection but can be provided on request. A further fishing heatmap for >12m vessels has also been provided in the supplementary report prepared by Poseidon and submitted to Argyll & Bute Council in February 2026. This confirms that there remains no significant displacement predicted as a result of the proposed changes, considering all available information. Page 27
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Officer comment: these matters provide further reassurance that the impact on commercial fisheries has been fully considered and that any displacement of vessels is not significant given the extent of fishing grounds in the Kilbrannan Sound. All other matters have already been suitably addressed in the Report of Handling and the Committee Report and do not result in a change to the officer recommendation. The full Applicant response to Cllr Tommy Macpherson is available on public access. 5. FURTHER MINOR REVISION TO CONDITION 18 Further minor revisions are proposed to planning condition 18 to ensure all local fishing vessels are included in ongoing liaison and to clarify types of vessels that will be facilitated access and the planning policy supporting this. 18. Local Fisheries Liaison Within three months of the date of this decision the applicant shall establish a forum for effective operational communication with local fishing vessels, including members of the Clyde Fisheries Association and if deemed necessary, agree a Fisheries Management and Mitigation Strategy. This forum shall be used to agree and implement proposed operational mitigation mechanisms in relation to sharing of installed mooring anchor coordinates and the provision of enhanced navigational lighting and anchor markers where possible. Reason: In order to support co-existence of local fisheries and salmon farming on this site and ensure both navigational and fish pen containment safety while maintaining as much access to fishing grounds for creeling and other fishing vessels as is reasonably practicable in line with the provisions of LDP2, NPF4 and The National Marine Plan. 18. Local Fisheries Liaison Within three months of the date of this decision the applicant shall establish a forum for effective operational communication with the members of the Clyde Fisheries Association and if deemed necessary, to agree a Fisheries Management and Mitigation Strategy. This forum shall be used to agree and implement proposed operational mitigation mechanisms in relation to sharing of installed mooring anchor coordinates and the provision of enhanced navigational markers for anchor markers where possible. Reason: In order to support co-existence of local fisheries and salmon farming on this site and ensure both navigational and fish pen containment safety while maintaining as much access to grounds for creeling and other fishing vessels as is reasonably practicable in line with the provisions of The National Marine Plan. 6. POLICY ASSESSMENT The representations and further submissions received since the December PPSL meeting do not raise any new material planning considerations over and above those fully assessed within the previous Report of Handling/Committee Report and Supplementary Report 1. The further clarifications on data used in the previously submitted Commercial Fisheries Report are useful and the additional analysis of the impact of the proposal on commercial fisheries provides reassurance that the localised commercial fisheries impact will be minimal in the context of the wider fishing grounds available in the Kilbrannan Sound. Page 28
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It is noted that there has been ongoing dialogue between the applicant and the main objecting party, the CFA who represent local fisheries, throughout the planning process. In response to these ongoing discussions, the proposal’s moorings have been redesigned to reduce the impact of the proposal on local fishing grounds. The applicant has also committed to facilitate safe access to grounds near to the proposed boundaries for those smaller vessels using mobile fishing gear and a number of mitigation measures - including sharing of the anchor co- ordinates and safety buoy lighting are proposed to be implemented through planning conditions. Furthermore, Condition 18 is intended to ensure that the mitigation offered by Mowi to the local fishing boats is effectively secured and that communication continues to facilitate safe co-existence of aquaculture and local fisheries. Condition 18 includes provisions for a Fisheries Management and Mitigation Strategy if deemed necessary, to address the requirements of the National Marine Plan in instances where existing fishing opportunities or activity cannot be fully safeguarded. It is noted that strategies such as this are usually reserved for much larger and new marine developments. As such, the proposal fully complies with Argyle and Bute Local Development Plan 2 Policy 28 - Supporting Sustainable Aquatic and Coastal Development and other relevant LDP2 policies. The proposal is considered to comply with the provisions of the National Planning Framework 4 Policy 32 – Aquaculture and is also in compliance with the relevant provisions of the National Marine Plan – specifically policies FISHERIES 2 and FISHERIES 3 of Chapter 6: Sea Fisheries. There is an existing operational fish farm in this location and the proposal represents a minor relocation of the site centre 79m to the east. The proposals are part of a wider modernisation plan that is beneficial in terms of fish health, operational efficiencies and health and safety of site workers, and which supports a key local employer and local, regional and national economic contributor. Therefore, officers consider there are insufficient grounds to recommend refusing the application. 7.0 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 1. Author of Report: Shelley Gould Date: 26.03.2026 Reviewing Officer: Sandra Davies Date: 26.03.2026 Fergus Murray Head of Development and Economic Growth Page 29
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Appendix A: Further commercial fisheries impact analysis of the proposed boundary changes. Page 30
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Appendix B: Further consultation undertaken by applicant with local fishermen of vessels <12m using mobile fishing gear (hand annotated maps) Page 32
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CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 24/01382/MFF Standard Time Limit Condition (as defined by Regulation) Additional Conditions 1. PP - Approved Details & Standard Notes – Non EIA Development The development shall be implemented in accordance with the details specified on the application form dated 3.7.2024, supporting information and, the approved drawings listed in the table below unless the prior written approval of the Planning Authority is obtained for an amendment to the approved details under Section 64 of the Town and Country Planning (Scotland) Act 1997. Plan Title. Plan Ref. No. Version Date Received General view and location of Carradale fish farm site location Annex 1: Figure 1 0001 16.9.2025 Existing site location (installed) (1:8,000) (dated 4.10.2024) Annex 1 16.9.2025 Existing (installed) & Proposed site (1:8,000) (dated 24.3.2025) Annex 1 16.9.2025 Proposed site (1:8,000) (dated 24.3.2025) Annex 1 16.9.2025 Admiralty Chart Proposed site (1:25,000) (dated 24.3.2025) Annex 1 16.9.2025 Proposed equipment co-ordinates Annex 1 16.9.2025 Existing equipment co-ordinates Annex 1 16.9.2025 Existing elevations – configuration 120m pens in 75m matrix grid (dated 11.7.2022) Annex 2: Figure 1 0001 31.7.2024 Proposed elevations - configuration 160m pens in 100m matrix grid (dated: 2.4.2020) Annex 2: Figure 2 10.10.2024 Manufacturers Diagram - Typical Moorings Design (dated 2.4.2020) Annex 2: Figure 5 0001 31.7.2024 Manufacturers Diagram – Net Design (dated 2.4.2020) Annex 2: Figure 3 0001 31.7.2024 Manufacturers Diagram – Top Net Support Structure (dated 7.5.2021) Annex 2: Figure 4 0001 31.7.2024 Manufacturers Design Specification – 160m pen (dated 17.6.2021) Annex 11 14.10.2024 Existing feed barge photographs (dated October 2024) Annex 10 14.10.2024 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. Acoustic Deterrent Devices No Acoustic Deterrent Devices (ADDs) shall be deployed at the site hereby approved. Reason: In the interests of nature conservation. This planning application has been assessed on the basis that ADDs will not be used. The use of ADDs would be regarded as a material change to the proposal. Page 34
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3. Biomass and Stocking The development hereby approved shall not be operated other than with a biomass of 2500 tonnes or less and shall only stock one species of fin fish (other than cleaner fish). Reason: The environmental effects of this proposal have been assessed against this maximum biomass of one species. 4. Fallow Period There shall be a minimum of 28 days in each calendar year when the site will be fallow and this shall be applied synchronously with the other fish farms within the Kilbrannan Sound FMA. Reason: In the interests of nature conservation. 5 Removal of Existing Equipment Prior to the development hereby approved being brought into use, the redundant equipment relating to the previous layout shall be removed from the site. In the event that the development or any associated equipment approved by this permission ceases to be in operational use for a period exceeding three years, the equipment shall be wholly removed from the site thereafter, unless otherwise agreed in writing by the Planning Authority. Reason: In the interest of visual amenity and to accord with LDP2 Policy 29. 6. Redundant Equipment/Equipment Failure In the event of equipment falling into disrepair or becoming damaged, adrift, stranded, abandoned or sunk in such a manner as to cause an obstruction or danger to navigation, the developer shall carry out or make suitable arrangements for the carrying out of all measures necessary for lighting, buoying, raising, repairing, moving or destroying, as appropriate, the whole or any part of the equipment. Reason: In the interest of visual amenity and safe navigation. 7. Finished Surfaces The finished surfaces of all equipment above the water surface, excluding the feed barge, but inclusive of the surface floats and buoys associated with the development hereby permitted (excluding those required to comply with navigational requirements) shall be non-reflective and finished in a dark recessive colour unless otherwise agreed in advance in writing by the planning authority. Reason: In the interest of visual amenity. 8. Lighting All lighting above the water surface and not required for safe navigation purposes should be directed downwards by shielding and be extinguished when not required for the purpose for which it is installed on the site. Page 35
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Reason: In the interest of visual amenity and navigational safety. 9. Noise The Noise Rating Level attributable to the operational activities associated with the approved fish farm shall not exceed background noise levels by more than 3dB(A) at any noise sensitive property measured and assessed in accordance with BS4142:2014. Reason: In order to protect the amenities of the area from noise nuisance. 10. Proactive notification of fish movement operations The applicant shall provide the dates of any planned fish movements utilising large vessels in a year in advance in writing to the Planning Authority. Reason: In the interests of improving monitoring and reducing impacts on amenity. 11. Hours of operation Except where the planning authority has been notified under the provisions of condition 10 or in situations outwith the applicant’s control (e.g. tidal conditions, fish movements delayed by bad weather or fish health interventions); no operations, other than water pumping, feeding, servicing, environmental monitoring and maintenance testing of plant/equipment shall take place on site outwith the following times: 07.00 hours to 20.00 hours over 7 days. Reason: In the interests of amenity. 12. Mitigating impacts of operations (including out of hours and Well Boat operations) All site operations including: • the use of equipment integral to the production cycle (e.g. underwater lighting and aeration systems or well boats) which is required to run overnight for fish health reasons; • operations notified under the provisions of condition 10; and • any fish health interventions or delayed operations out of hours, shall adhere to the best practice measures detailed in the ‘Further Supporting Information - mitigation of amenity impacts arising from operational effects’ document (submitted by MOWI on 12.9.2025). All delayed or out of hours operations required to be undertaken outwith the provisions of condition 10 shall be recorded by the applicant. A record of these out of hours activities shall then be made available to the Planning Authority on request. Reason: In the interests of improving monitoring and reducing impacts on amenity. 13. Environmental Management Plan (EMP) The development site shall be operated in accordance with the submitted Environmental Management Plan (Kilbrannan Sound EMP (8.2.24). The EMP should be reviewed and updated if required following the adoption by Scottish Government of any new policy framework relevant to sea lice management and wild salmonid interactions. Any proposed amendments to the EMP Page 36
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shall be submitted to and approved in writing by the planning authority prior to the changes being implemented. Reason: In the interests of nature conservation and protecting the environment. 14. Waste Management Plan The development shall be carried out in accordance with the Carradale Waste Management Plan dated July 2024 or as updated and agreed in writing with the Planning Authority. Reason: To ensure that waste is dealt with in a sustainable manner in accordance with Development Plan policy. 15. Containment and Contingency Escapes Plan The development shall be carried out in accordance with the Containment and Contingency Escapes Plan dated April 2024 or as updated and agreed in writing with the Planning Authority. Reason: to maintain the integrity of the holding structures and the measures to be taken in the event of a suspected escape. The plan is specific to the proposed installation of 160 m circumference pens. 16. Sea Lice Policy Strategy and Efficacy Statement The development shall be carried out in accordance with the ‘Carradale Sea Lice – Policy, Strategy and Efficacy Statement’ dated October 2024 or as updated and agreed in writing with the Planning Authority. Reason: In the interests of nature conservation. 17. Biodiversity Enhancement Proposals Within 3 months of the date on this planning permission, a Biodiversity enhancement strategy shall be submitted for the approval of the planning authority. Thereafter the applicant shall implement the proposals in line with the approved strategy and provide updates at the request of the planning authority. Reason: In order to protect biodiversity, reverse biodiversity loss, deliver positive biodiversity effects and strengthen nature networks in accordance with the requirements of NPF 4 Policy 3. 18. Local Fisheries Liaison Within three months of the date of this decision the applicant shall establish a forum for effective operational communication with local fishing vessels, including members of the Clyde Fisheries Association and if deemed necessary, agree a Fisheries Management and Mitigation Strategy. This forum shall be used to agree and implement proposed operational mitigation mechanisms in relation to sharing of installed mooring anchor coordinates and the provision of enhanced navigational lighting and anchor markers where possible. Reason: In order to support co-existence of local fisheries and salmon farming on this site and ensure both navigational and fish pen containment safety while maintaining Page 37
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as much access to grounds for fishing vessels as is reasonably practicable in line with the provisions of LDP2, NPF4 and The National Marine Plan. Page 38