Public reports pack
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 605522 DX 599700 LOCHGILPHEAD 23 March 2026 NOTICE OF MEETING A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be held ON A HYBRID BASIS IN THE COUNCIL CHAMBER, KILMORY, LOCHGILPHEAD AND BY MICROSOFT TEAMS on MONDAY, 30 MARCH 2026 at 10:30 AM, which you are requested to attend. Douglas Hendry Executive Director BUSINESS 1. APOLOGIES FOR ABSENCE 2. DECLARATIONS OF INTEREST 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 - 62) 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 63 - 122) 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. 1 1. INTRODUCTION This application is to be presented to the Planning, Protective Services and Licensing (PPSL) Committee on 17th December 2025. Following the publication of the Report of Handling, the Clyde Fishemen’s Association (CFA) has submitted two further representations to the Council, each reiterating their position of objecting to the proposal as follows: Email from CFA of 10.12.2025: • [Condition 18] Mentions creel vessels, CFA represents both methods of fishing, but its primarily mobile boats who will be impacted by the encroachment into tows. • We've already had productive liaison with MOWI, but [the proposal] will have a significant impact to local fishing boats if approved as proposed in that location. Proposing more liaison after approval will not make it a better fit for fishermen who oppose its new location. As noted they feel a compromise is already the current site. • There is significant feeling from local fishermen of frustration that other regions seem to be changing approach to balance fish farming and wild fishing. This is more often now leading to less approvals on new aquaculture developments, this doesn't seem to be happening in Argyll and Bute in the same way. • We are trying to support sustainable development in wild fishing in Argyll and Bute, but decisions between wild fishing and aquaculture seldom if ever seem to fall on the side of wild fishing, and this is harming the case of co-existence. • 16 safety claims around the country are now being contested as boats are caught in aquaculture kit regularly, most often outwith the limits of the site. • Local fishermen are not happy with the current situation. Page 3 Agenda Item 3
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Email from CFA of 15.12.2025: • Proposal does not represent a minor relocation to fishermen at all, and we are concerned you would think that is the case for our members. These are local fishermen who already have government license to fish, and have been fishing here for many years. This past week alone three boats have been in the area continually, each with an average crew of around 4 people employed, and more boats will be significantly impacted than those fishing there this week alone. • Fishing is not about how much marine area you can access, it is about the safe and productive grounds, and they are not just anywhere in the sea. You can have vast areas of sea and seafood is only caught in a small area. The area of the proposed relocation of the farm is without question encroaching on provable productive and safe fishing grounds, and so it is in no way a minor relocation for our members, it's a significant loss. • If a farmer works 40 acres and 2 are arable and productive, and a shop receives planning permission to be built on the 2 arable acres which are worked, the farmer will still lose most of his living. It doesn't matter if he has another 38 acres which can't be worked. Discussing the fence parameters of the shop building with the farmer after the build will not benefit the farmer much as his productive land is already lost. This is a similar principle for fishing, except we have the added risk of danger in losing safe and sheltered waters. Sorry to have to scenario plan with on land examples, but this understanding doesn't seem to be widely comprehended by many parties in the marine development space. • We have absolutely provided detail of example fishing tows which this proposed development to both MOWI and the Council, and so all parties are aware that wild fishing is happening and important to local fishing businesses. Indeed fishermen have relayed this directly to MOWI in meetings, and their individual objections to the site directly to the Council, of which I believe at least 11 were received. Local boats are happy to meet with planning officers or Councillors to explain their loss of income and provide accounts. • Often aquaculture developments have site visits for Councillors when proposals are put forward and we are happy to present the wild fishing side via a boat visit, indeed we hope that would bring more understanding and balance. • Landing details and the turnover of the businesses who rely on the catch nationally have been provided, and links to landing stats which are available through the Seafish site and the Scottish Government directly online. There are no figures for the haulage of seafood specifically in Argyll and Bute but it will also be significant as catch is transported from Argyll and Bute to the Central Belt, Northern Ireland and the EU. • The approach we have taken is similar to that taken by Western Isles Fishermen's Association in the Outer Hebrides. WIFA are my colleagues and we work together as sister Associations, however their perspective clearly held more weight with their local council representatives, perhaps because the value of fishing is more closely understood in the Outer Hebrides by its government representatives working with the fishing community. • I think we genuinely have to work more closely so we can help Argyll and Bute Council Planning to understand the value chain of wild fishing in more detail. We want to help where we can, and our members can't afford for there to be any misunderstandings or under estimations regarding the worth of local wild fishing. The Western Isles proposal was a new development, but that makes little difference as the principle is still the same. Important ground will be taken away from wild fishing, and as already explained productive fishing ground is not about sqm meters. Perhaps in a way its more jarring as there is already a suitable MOWI site operating in the area, which fishing try to work with. This feels like pushing a workable compromise into an uncomfortable place for fishermen. We have recently worked with another Salmon Company on a full new site Page 4
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location, and our members had no objections It’s not always the size of the footprint, it’s were its located, and this is a move is straight into valuable traditional fishing grounds. • The evidence is without refute that important fishing areas will be lost, and so it follows that the income of existing local fishing businesses will be reduced, and the wider businesses who rely on them will reduce too. Fishing is a sum of parts making a whole, if you take sections of the business away it can and has resulted in a loss of sustainable family and community businesses/boats, and in this case where aquaculture and fishing are already neighbours and working well this doesn’t seem sensible to us for the area. Better to have a balanced and mixed economy. • We provided the turnover of businesses like Whitby, SFO, West Coast PO, Angelbond and Youngs, all of which our members produce goes too. It's clear these are significant businesses with substantial turnovers, and our member boats help to create those figures from local areas such as this site. We believe this recommendation to support this proposal is a choice to reduce one sectors income and potential to support the growth of another's, and that must be acknowledged. We can't accept we haven’t provided adequate information to prove a negative impact to local fishing, we have. At the moment both sectors are co-existing in the area and this will cause significant avoidable tensions. • MOWI commissioned consultants in Poseidon to look at fisheries and their proposal. Firstly we had very little time to respond to that report, only days for a 50 page report we hadn’t previously seen, so from the start the procedure was very rushed for us. However we did take the time, and we clearly pointed out a number of significant issues with the report including the fact that under 12m boats aren't even captured, and neither the socio-economics of wild fishing in processing, haulage or exports, as it is captured for MOWI. This is not a like for like socio-economic comparison. Only fisheries landings have been compared with a full value chain for MOWI. It is often noted that for every 1 job on a fishing boat around 5 to 8 jobs are related on land (depending on the boat and the economist). No fishermen in our association were approached in the creation of the Poseidon report, and we would recommend looking at value chains of fishing from netmaking, catching, boat yards/engineers, fuel merchants, haulage, exporting, processing, policy development, science and retail to get a picture of the wild fishing chain our members are part of: Fishing data and insight | Seafish • We would certainly be interested in how MOWI justified their projected figures and how they were asked to confirm these projections were accurate? How many new jobs did they say this proposal would create, or would it be existing employees? How many employees will be local to the area or brought in? What new revenue will it bring to the area and how is that proven? • Also can we ask what creelers noted this proposal would be a benefit? As both our creel and mobile members have expressed they are not supportive of this proposal. It would be interesting to see if this is in fact a full time commercial creel fisherman from the area who has said this is beneficial. • We have concerns as at a previous Council meeting for another aquaculture site we were informed in the public meeting that Carradale Fishermen’s Association supported the development, but there is no such organisation. In addition all of the boats relevant to that previous proposal were in the Clyde Fishermen’s Association and against it. We are worried that perhaps a recreational fishermen, or maybe just a member of the public, has been approached and represented as “local creelers”. Particularly given the claims made previously. • Was any explanation provided for change to the site in light of the significant market reduction in Salmon at the moment? https://share.google/h1iN7d94YvOZ3Noc0 • The potential for wild fishing to grow and develop in Argyll and Bute is significant and we want to be an asset to Argyll and Bute and work with you and partners, as the Page 5
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Vision Document we provided shows. We have and will compromise with other sectors where possible, but for our fishermen this is an unfair ask for their sustainability. • At the moment around the coast there are 16 instances of unresolved disputes between fishing boats and aquaculture sites which we are aware of. For example fishing boats claiming they have been caught in unmarked fish farm kit outside the designated locations, and in some instances disputes over thousands of pounds damage to boats and potential risks to life has been created. It’s clear that tensions are rising in some regions, and we would be inclined to suggest where a current compromise is working to an extent for both parties, that would be the best option to continue with rather than moving aquaculture into known wild fishing areas. We aren’t campaigning against the current site and we would rather have a good working relationship if possible with mutual respect for both sectors. • In the National Marine Plan (. 6. Sea Fisheries - Scotland's National Marine Plan - gov.scot ) it notes that: “Existing fishing opportunities and activities are safeguarded wherever possible”. It goes on consideration must be given to: “The cultural and economic importance of fishing, in particular to vulnerable coastal communities”. It also notes that where it is not possible to safeguard wild fishing then a Fisheries Management and Mitigation Strategy should be prepared, and that: “Where it does not prove possible to agree the Strategy with all interests, the reasons for any divergence of views between the parties should be fully explained in the Strategy and dissenting views should be given a platform within the Strategy to make their case” • Firstly we do not believe that existing wild fishing opportunities and activities have been safeguarded wherever possible in this case, it's entirely possible to keep the status quo and have aquaculture and fishing in the area as is. Instead we are probably moving from a space of co-existence between local wild fishing and aquaculture to competitive issues for space, which is not an ideal scenario for those working at sea. • We have made it clear that we do not agree with the proposal and have highlighted a range of justifiable issues with the Poseidon [commercial fisheries Impact assessment] report, some of which the consultants raised themselves re data gaps. Aside from the short time in which we had to read it. However we have not been meaningfully involved in a Strategy or had the opportunity to directly put our own views forward in a platform in any Strategy to make our case, as far as we are aware this seems to be a missing step? I would not say that Clause [Condition] 18 addresses those points outlined. • Can we be advised on what steps we can now take to continue to object formally? The purpose of this Supplementary Report is to update elected members on details of further representations submitted Clyde Fishermen’s Association, to identify where matters have been adequately dealt with in the Report of Handling and Committee Report, to clarify where there are new matters and to detail any appropriate response to these matters on the part of the applicant. Officer comment: these matters have already been suitably addressed in the Report of Handling and the Committee Report and do not change the officer recommendation. Where relevant, the applicant provides further detail on technical matters below. 2. APPLICANT RESPONSE TO CLYDE FISHERMENS’ ASSOCIATION (16.12.2025) This application is for a site modification with a change in area and thus should not be compared with or considered in the same light as a new site proposal. Purpose, Employment & Investment Page 6
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Fundamentally, the purpose of upgrading Carradale sites to fewer 160m pens is to support fish health through optimised operational efficiency. The investment in fewer, larger pens at our Carradale sites aligns with Mowi's strategy to effectively utilise modern pen technologies, maximising the efficiency and effectiveness of fish health management and site operation. This pen upgrade forms part of a wider Carradale enhancement project, which Mowi have been investing in significantly, including development of the North Kilbrannan farm, local community investment, a new shorebase, house restoration, and harbour upgrades, including a shared use pontoon. Mowi has developed a plan for the transition of suitable sites to fewer, larger pens, and Carradale North and South fit the profile for such a site. The use of 160m pens has been very common in Norway over the past 10 years but has only recently been fully embraced in Scotland, delayed mainly by a lack of service infrastructure to deploy, manage and harvest from this size of pen. In recent years though significant investment has been made by Mowi in service vessels, workboats and well boats of a suitable mass that can now handle larger sized pens and associated equipment. In addition, there are operational and resourcing benefits, including fewer nets for inspection and reduced maintenance such as net cleaning, improving localised water quality and associated gill health. In terms of the specific pen centres that are presented, this is a combination of minimising the planning boundary change requested vs existing layouts, whilst bearing in mind the water column depths required for safe instalment of the larger pen grid to support the larger pens. On the inshore side of the pen groups, the bathymetry shallows quite rapidly, and we must maintain a minimum depth on that side, so we cannot move the pens any further shoreward. Instead, to minimise the farm footprint we have endeavoured to reduce the eastwards side moorings as far as practicable. This creates the specific layout presented today. A socio-economic statement was submitted to Argyll & Bute Council as supplementary material in September 2025. Engagement The importance of engaging with commercial fisheries was brought to our attention by the planning committee during our historical North Kilbrannan application, and we have consciously worked to improve engagement as a consequence of this. Our register of engagement captures 17 key interactions upto July 2025 with the CFA. As shown in this register, and via our iterative application process, Mowi have attempted to work with CFA to develop a design for the 160m pens that is both effective and safe from an operational and moorings' perspective, and sympathetic to existing fishing practices. This has involved communication both with CFA representatives, and directly with individual members. Amendments Most significantly, consultation has led to two re-submissions, and a significant reduction of the site moorings by Mowi (submitted Oct 2024, and Sept 2025). Engagement with our moorings designers has allowed us to reduce the proposed site on the eastward side to a minimum, whilst retaining an effective and safe mooring solution. This is at the economic expense of Mowi, as it is made possible by using more heavy duty, expensive solutions. The specific pen centres proposed are designed based on the minimum possible change to existing pen locations, and considering the requirements for certain depths for the pens themselves, as well as effective and reliable moorings. To reiterate, this is now a distance of just 79m for the Carradale North pen group, and 99m for the Carradale South pen group. Following presentation of this compromise, CFA indicated that they would sustain their objection. National Marine Plan: Fisheries Management and Mitigation Strategy (FMMS) FMMS are typically utilised for much larger developments where there is potential for large scale interactions with commercial fisheries, e.g. major offshore wind developments. It is not Page 7
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standard practice for Mowi (or any aquaculture development) to require such a strategy, although they could be adapted to be more appropriate to this scale of development, if deemed necessary. CFA should be reassured that they have not been denied the opportunity to feed into such a document. Mowi does have experience of developing such a document at one fish farm (a new site development), and this was developed after the development was determined. Mowi would be content for this to be included as an item within clause 18, should it be deemed necessary. Creel Fishing In response to CFA's land-based farming example, we do not see that the seabed is directly comparable to arable/land-based farming. Firstly, the area is not privately owned by either party and does not have defined/fenced boundaries within which fish and shellfish do or do not travel. Indeed, Mowi has witnessed anecdotally that the no-take zones created through our mooring installations, can create enhanced productivity for some species, including commercially important langoustine, lobster, crab and white fish species. Indeed, this effect appeared to be recognised in a meeting with CFA members on the 02.02.2024, when a creel fisherman indicated that he currently shoots his creels close to the existing Carradale moorings (inshore side) for best fishing success. Following this discussion, to endeavour to facilitate this fishing practice most safely, Mowi agreed to send a detailed list of moorings coordinates by email to this individual, and also to send an amended list following installation of the proposed 160m pen mooring grid, if approved. There was verbal agreement from both parties in the same meeting that, since the 160m pen application would create a slight increase in the inshore fishing area, this may offer additional creel fishing grounds. This interaction was perceived by Mowi to indicate a positive response to the proposal by the creel fishermen represented in the meeting. The email exchange and identity of individuals is not shared for data protection reasons. Communication & Disputes Although CFA refer to 16 open disputes between fisheries and aquaculture nationally, we can confirm that Mowi are not aware of any unresolved disputes at this time and have a dedicated pathway to facilitate open communication if any issues are to arise, to ensure they are dealt with in a timely and satisfactory manner. Separate to the development and the planning application, Salmon Scotland, its producing members, and representatives from relevant Fisheries Associations (SFA, OFA, WIFA, CFA, CIFA, SFF) have all agreed to create a series of engagement liaisons, starting in 2026, with a focus on recognising the challenges faced by both sectors, and exploring solutions and opportunities. 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 finfish aquaculture across Scotland. Currently, the group’s objectives are to identify and discuss effectively on issues arising from the interaction of the fishing and finfish aquaculture activities, and to 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 safety. Commercial Fisheries Impact Report & Recent fishing tracks The Commercial Fisheries Impact Report by Poseidon considers public commercial fisheries data. It explains the sources of information available and utilised, and acknowledges data limitations that exist across the whole of Scotland. Therefore the uncertainties faced around untracked vessels and public data are not specific to the Development under consideration. The Report by Poseidon details that “Mowi have stated that they would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels”, thereby working to mitigate interactions with small vessels. Page 8
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In addition, Mowi have reviewed available track data for vessels of interest today, for the preceding 30 days, as far as is publicly available. The vessels referred to by CFA as being active in the area in the past week are not visible in this data. Therefore it is assumed that these boats are less than 12m in length and thus not tracked. This presents data uncertainty, as is the case across Scotland and the regulatory framework. Smaller vessels, if creeling, are expected to be able to continue to operate in close proximity to the farm and as mentioned in the ‘Creeling’ section above, we expect they may actively seek out these waters, and we are willing to facilitate this. As shown in the plot below, six vessels were active in the last 30 days, and only one tracked vessel has passed within the proposed moorings boundary, on the 27th Nov (and close by on 26th Nov). This vessel was travelling at an average speed of 7.4kn, which we assume is indicative of transiting and not active fishing. There are other tracks in the centre of the deep channel that are more indicative of fishing (~2.2kn speed). Local contacts in the Carradale area have also been consulted today regarding recent fishing activities and confirmed that no fishing vessels have been noted adjacent to the existing site, however any that are within a reasonable distance of the area (~1km) are creel vessels. Page 9
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Officer comment: these matters have been suitably addressed and do not change the officer recommendation. 3. ASSESSMENT AGAINST THE NATIONAL MARINE PLAN Officers are of the opinion that the applicant has taken all reasonable endeavours to safeguard existing fishing opportunities by responding to the issues raised by the CFA. Specifically, the applicant has undertaken the following steps in response to concerns raised: 1. Engaged with CFA at pre-application stage and throughout. 2. Undertaken detailed moorings analysis and reduced the areas of moorings by 14% in response to concerns raised. 3. Submitted amended plans to accommodate reduced moorings areas. 4. Undertaken Commercial Fisheries Impact Report. 5. Agreed to further mitigation measures to facilitate safe access to creeling grounds close to the proposed new pens. 6. Agreed to planning condition 18 which aims to ensure the proposed mitigation is implemented and further dialogue is possible to enable ongoing co-existence between the two sectors. However, in this instance, the CFA does not agree that existing wild fishing opportunities and activities have been safeguarded and would prefer to keep the status quo, with no changes to the existing Carradale Fish Farm. The CFA also does not consider that they have been meaningfully involved in a Strategy or had the opportunity to directly put their views forward in a platform in any Strategy. The applicant would dispute this, given the ongoing engagement, however, The National Marine Plan sets out that: “Where existing fishing opportunities or activity cannot be safeguarded, a Fisheries Management and Mitigation Strategy should be prepared by the proposer of development or use, involving full engagement with local fishing interests (and other interests as appropriate) in the development of the Strategy. All efforts should be made to agree the Strategy with those interests. Those interests should also undertake to engage with the proposer and provide transparent and accurate information and Page 10
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data to help complete the Strategy. The Strategy should be drawn up as part of the discharge of conditions of permissions granted.” The National Marine Plan further sets out that the content of the Strategy should be relevant to the particular circumstances and could include: • An assessment of the potential impact of the development or use on the affected fishery or fisheries, both in socio-economic terms and in terms of environmental sustainability. • A recognition that the disruption to existing fishing opportunities/activity should be minimised as far as possible. • Reasonable measures to mitigate any constraints which the proposed development or use may place on existing or proposed fishing activity. • Reasonable measures to mitigate any potential impacts on sustainability of fish stocks (e.g. impacts on spawning grounds or areas of fish or shellfish abundance) and any socio-economic impacts. Where it does not prove possible to agree the Strategy with all interests, the reasons for any divergence of views between the parties should be fully explained in the Strategy and dissenting views should be given a platform within the Strategy to make their case. The applicant is content to work with the CFA on the production of a Fisheries Management and Mitigation Strategy if deemed necessary and this is to be secured by condition 18 as suggested in the National Marine Plan. As such officers are satisfied that all reasonable measures have been undertaken to ensure co-existence between aquaculture and local fisheries. 4. MINOR REVISIONS TO CONDITION 18: In response to these further representations to the Council, the applicant has agreed to produce a Fisheries Management and Mitigation Strategy if deemed necessary and this is to be secured by minor revision to planning condition 18 as follows (additions in bold): 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 fishing grounds for creeling and other vessels as is reasonably practicable in line with the provisions of The National Marine Plan. Officer response: These matters do not raise any new concerns that have not already been dealt with in the Report of Handling and PPSL Committee Reports and addressed where relevant through the use of planning conditions or revised planning conditions. 5. CONCLUSION Given there is an existing operational fish farm in this location, it is a minor relocation of 99m to the east as part of a modernisation plan and we have not been able to fully Page 11
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quantify the local financial impact of the potential loss of fishing grounds specifically linked to the changes proposed, officers feel there are insufficient grounds to recommend refusing the application. We note that there has been ongoing dialogue between the applicant and the CFA throughout the planning process and Condition 18 is intended to ensure that the mitigation offered by Mowi to the local fishing boats is implemented and communication continues to facilitate safe co-existence of aquaculture and local fisheries. The revisions to Condition 18 to implement a Fisheries Management and Mitigation Strategy if deemed necessary, adequately address the requirements of the National Marine Plan in instances where existing fishing opportunities or activity cannot be safeguarded. Author of Report: Shelley Gould Date: 16.12.2025 Reviewing Officer: Peter Bain Date: 16.12.2025 Fergus Murray Head of Development and Economic Growth Page 12
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LDP2 format template Nov 2023 Argyll and Bute Council Development & Economic Growth 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 Planning Hierarchy: Local Application 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 DECISION ROUTE ☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 ☒Committee - Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • Modification of existing pens 10 x 120m circumference to 6 pens 8 x 160m circumference pens in a 120 m x 120 m mooring grid matrix, held in two linear rows of 4 pens; • Installation of pole mounted top nets; • Minor relocation of the existing and installed 600 tonne feed barge (ii) Other specified operations • Navigational lighting in accordance with the requirements of the NLB. • Biomass of 2,500 tonnes (B) RECOMMENDATION: It is recommended that: Planning permission be approved subject to the conditions and reasons appended to the report. (C) CONSULTATIONS: Marine Directorate of the Scottish Government (dated 7.11.24): The two pen groups at Carradale North and South are registered as one site with Scottish Ministers in the applicant’s aquaculture production business authorisation. Therefore, the Fish Health Page 13
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LDP2 format template Nov 2023 Inspectorate (FHI) have considered these concurrent applications together and provide combined comments for these applications (ref: 24/01381/MFF and 24/01382/MFF). Summary of information required • Confirmation of net depth • Details of the practical time taken to perform physical treatments on the modified site • Details of the permitted quantities of chemotherapeutants on the South pen group and the practical time taken to conduct these treatments Marine Directorate of the Scottish Government (dated 11.12.24): Having reviewed the further information submitted by the applicant on 03/12/2024 the following comments are made: Confirmation of net depth Depth of net sidewalls is confirmed as 12m for inside pens and 15m for outside row of pens. This is satisfactory for an acceptable stocking density level of below 22kg/m3. Details of the practical time taken to perform physical treatments on the modified site - The FLS system can treat 3x 160m pens per day, so could complete treatment of each pen group in 2 days and the whole site in 4 days. Details of the permitted quantities of chemotherapeutants on the South pen group and the practical time taken to conduct these treatments The revision to the permitted quantities of bath chemotherapeutants in the new CAR licence application would allow bath treatments of azamethiphos to be undertaken on the North or South pen group at a rate of 1 pen/day equating to 6 days for each full pen group. It is noted that the pen groups may not discharge azamethiphos at the same time, therefore should treatment of both pen groups be required for the whole site this would take 12 days. Consented levels for the in-feed treatment emamectin benzoate allows one use per cycle on each of the North and South pen groups at maximum biomass or more frequent uses earlier in cycle when biomass is lower, as it has been utilised in this manner in recent production cycles. Sea lice efficacy The CAR licences for both sites permit sufficient quantities of Azamethiphos and Deltamethrin to allow the treatment of each site within 6 days and 3 days respectively with tarpaulin treatments. The applicant has indicated that the Modelled Maximum Quantity of the in-feed treatment Emamectin benzoate (SLICE) is sufficient for a single treatment at maximum biomass (at each site). Given the exposed location of the site, there are concerns over the welfare of young fish being stocked on site and their ability to withstand the currents and environmental conditions experienced on site. It is noted the applicant state that larger smolts will be stocked onto the site; the production plan details that the average size of smolts being stocked will be 164g, with a production cycle of up to 18 months. Details of the considerations made on the suitability of the site for fish of this size whilst ensuring any impacts to welfare are mitigated against should be provided. This information may be included in the Veterinary Health and Welfare Plan which is referenced but not provided. No further information required. Scottish Environmental Protection Agency (dated 29.10.24): We have no objection to the proposed development from a planning perspective. We can confirm that we have already authorised the change under CAR. Page 14
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LDP2 format template Nov 2023 Argyll and District Salmon Fishery Board (dated 24.10.24): Our consultation response to the application is made in respect to the importance of populations of Atlantic salmon present in the rivers of Kintyre and Isle of Arran, and several smaller coastal rivers that also support populations of sea trout which support active recreational fisheries, local employment, and economy. Our primary interest remains the reduction of pressure on wild salmonids from sea lice and escaped farm fish, and we broadly support innovation in the aquaculture sector to develop production methodologies which can mitigate for impacts on wild fish. In principle, Argyll DSFB have no objection to the change in fish pen sizes. However, on the premise that the potential failure in containment in one of the six larger cages proposed may pose some increased risk of interactions with wild fish populations given that a higher number of post-smolt salmon will be held in fewer, but larger pens. We also note and appreciate the measures described in the escapes contingency plan provided with the application which detail measures to reduce the potential for escapes of farm stock to occur. We are, however, mindful that escapes of farm fish remain a possibility as there has been a significant escape of farm fish from this site in recent years. We appreciate the most recent equipment designs may improve containment measures but the risk to wild salmon populations remains. We are, however, mindful that escapes of farm fish remain a possibility and that we need to be assured that the containment measures put in place are sufficient to protect local wild salmon populations over time. To this end we ask that a regular programme of genetic surveillance of local wild salmon populations is undertaken over the lifetime of the farm. This programme of genetic monitoring should be capable of identifying any introgression of escapee farm salmon with wild salmon populations in the area. Argyll DSFB, expect such a programme of surveillance to be embedded within an Environment Monitoring Plan (EMP). In summary, Argyll DSFB has no objection to the proposed change in fish pen size at the Carradale farm site in the understanding that an EMP that monitors the genetic health of wild salmon populations in the Awe Fisheries District is a condition of any change in the planning permission. Argyll Fisheries Trust: No response. NatureScot (dated 15.10.2024): Confirmed no comments. Historic Environment Scotland (dated 30.10.24): Confirm that there are no marine or terrestrial heritage assets within statutory remit within the development site boundary or within its vicinity. No comments. West Highland Anchorages and Moorings Association (WHAM) (15.10.2024): no comment. Northern Lighthouse Board (dated 18.10.24): Consultation response includes details of lighting and marking requirements. Royal Yachting Association (dated 30.10.24): RYA Scotland has no objection to this application. However, it is noted that the outer perimeter of the farm will extend 85 m further east into the busy Kilbrannan Sound. It will be important to ensure that this expansion is widely publicised including through an update to the Clyde volume of the Clyde Cruising Club Sailing Directions and Anchorages book and that care is taken to ensure that the lights are well maintained at all times as a failure could have unfortunate consequences in conditions of poor visibility. Page 15
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LDP2 format template Nov 2023 Marine and Coastal Development Policy Officer (dated 18.11.24): There is no objection to the proposed changes at Carradale South fish farm. In terms of possible containment failure, I do however agree with the Argyll District Salmon Fisheries Board (ADSFB) in that it will be important for the Applicant to monitor the genetic health of local wild salmon populations through a programme of genetic surveillance. This should be stipulated within the Applicant’s Environmental Monitoring Plan (EMP). Planning conditions to be applied to the Carradale South Fish Farm 1. The Applicant is asked to submit their EMP. 2. The Applicant will not use Acoustic Deterrent Devices (ADDs). If ADDs are proposed at the site at any time in the future, the Applicant must apply for a European Protected Species Licence from the Scottish Government Marine Directorate - Licensing Operations Team (MD-LOT); including immediate notification and an ADD usage report with daily logs to be communicated with NatureScot and the Planning Authority on request. 3. Daily recording of wildlife interactions (entrapment/entanglement) with the site and the reporting of data at six-monthly intervals. The six-monthly reports are to be communicated with NatureScot and the Planning Authority. 4. Immediate notification to NatureScot and the Planning Authority of wildlife entrapment/entanglement, as stipulated by NatureScot. 5. To implement a monitoring programme, as stipulated by NatureScot. 6. To implement adaptive management approaches based on monitoring findings (as agreed with NatureScot in consultation with the Planning Authority). Update: Having reviewed the additional supporting documentation submission from Mowi for both planning applications: 24/01381/MFF - Carradale South Fish Farm and 24/01382/MFF - Carradale North Fish Farm, there are no further comments to add. Clyde Fishermen’s Association (dated 1.11.2024 & 5.11.24): On this occasion efforts were made to inform the CFA of the plan for the extension. MOWI also listened to concerns and comments presented by the fishermen who attended a meeting in February 2024. MOWI also advised of their intention to submit plans and slight alterations they would make. So in respect to communication in this particular project it was improved in that dialogue did occur and we appreciated the mutual effort fishermen and MOWI made. However, unfortunately as an association our member feedback has been that they would have to object to the planning applications above in the strongest possible terms. They feel the current arrangement is already an existing example of sharing space and compromise which works to an extent for both parties, and this proposal would detrimentally harm fishing unnecessarily when both sectors can continue to exist under the current arrangements. The fishermen from our membership were clear at the online meeting in February 2024 that a move of the current site closer to the East and further into the deep water would cut into the main tows of the indigenous fishing fleet who rely on this area for their livelihoods. This area is vital to the socio-economics of local fishing communities. The feedback from local fishermen is that this area is essential to fishing and could not be lost without risking the viability of local productive fishing boats and the loss of jobs. It is prime fishing ground for catching fresh wild seafood. Whilst we appreciate MOWI have now presented a model which is reduced on their initially proposed Eastward move, in reality even the reduced Eastward expansion in into the deep fishing water is significantly detrimental to local fishermen, just as the original proposal also was. Neither new options work for local fishermen. Local fishermen are not simply being difficult as they currently work with a situation of compromise right now Page 16
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LDP2 format template Nov 2023 which is more palatable to most fishermen. The current MOWI site initially meant a loss of ground to local fishermen so many already feel a compromise and balance has already been reached. It should be noted that many fishermen do have environmental concerns regarding aquaculture, so a current working situation should not be underestimated in terms of its value for local stability of relations and food production. Local fishermen feel the fairest compromise has already been reached previously, and this would be that the site remains at its current location and does not extend onto another deeper footprint in direct conflict with fishing patterns. A continuation of the current situation would allow both aquaculture and local fishing to continue to co-exist in the area and work alongside in the same vicinity. The extension of the aquaculture site Eastward would be the expansion of one sector at the cost of another local sector. The CFA feel this proposal doesn’t make sense when the current activity sites of aquaculture and wild fishing in the area currently works to some degree for both sectors. We hope Argyll and Bute Council should want to maintain both of the sectors in the area with a degree of harmony or at least good relations, not sacrifice one for the expansion of the other if both can co-exist. We appreciate MOWI may be disappointed if they are not able to expand/move the site, but we must reiterate we feel a compromise has already been reached on balancing wild fishing with aquaculture in this location which saw local fishing curtailed a number of years ago. Concerns raised on the impact on local fishing tows at the proposed site as well as wider impacts on the fishing community at Carradale Harbour and the fishing which takes place here is an important employer of local fishermen, exporters and processors and retailers in both Carradale, Campbeltown and well beyond. Applicant response to CFA (22.5.2025): We understand the concerns expressed on spatial conflict by commercial fishing stakeholders. We also acknowledge the need to interact with other marine users who may be impacted by fish farming, including fishermen with a view to establishing mitigation that allows the shared use of the marine space, avoiding and minimising potential displacement effects. We have focussed on establishing design mitigation to ensure that the proposed mooring areas have the minimum spatial footprint whilst maintaining structural integrity to ensure containment at the farms. Through the design of the development proposals, we have worked to reduce the overall extent of the mooring areas, whilst ensuring that the mooring systems meet all required technical design standards and is capable of withstanding the physical characteristics of the development locations. There is no recognised single data source for establishing a locational baseline of commercial fishing activity, and there remains data uncertainty on frequency and intensity of fishing activity, however the information provided by the CFA on local fishing activity allowed for further modelling analysis and reduction of the moorings systems for each of the development locations. A reduction in the fish farm moorings area, from that presented in the respective planning applications is now proposed for both developments. A more detailed breakdown of the iterative changes in the extent of the respective moorings areas through the process for planning approval is presented below. Moorings Design Mitigation An initial, indicative moorings boundary for the Carradale fish farms was presented in the applications for screening submitted to Argyll and Bute Council, which were subject to Page 17
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LDP2 format template Nov 2023 consultation. Following screening and in response to comments received from the CFA, a consultation meeting was held with the CFA (and local members) on 2 February 2024 to discuss and understand fishing grounds and activity to the east of the fish farms. From the information presented on fishing grounds and use there was a commitment from Mowi to re-examine the extent of the mooring’s areas for each development with the aim to reduce their extent. Further moorings design modelling was undertaken which subsequently confirmed the ability to reduce the indicative moorings boundary by 250m on the deep water, eastwards side. In addition, the moorings boundary to the west of Carradale south was adjusted eastwards by 56m, to facilitate improved access for creel fishermen (as informed by CFA meeting, pers. comms.) on the inshore side of the fish farm. The amended moorings layout-boundaries for both Carradale North and Carradale South fish farms were then presented with the respective planning applications. The total development area (including moorings) for the original proposals subject to screening, was 0.826km2 for Carradale North, and 0.818km2 for Carradale South. Following consultation and the above revised technical moorings analysis, and as submitted for planning approval, the extent of the mooring’s areas were reduced to 0.471km2 for Carradale North, and 0.471km2 for Carradale South. Post planning applications submission and following further consultation advice from the CFA and provision of new data on fishing use of the area to the east of the fish farms, including fishing vessel AIS tracks, further moorings modelling was undertaken. The new fisheries data ensured that the modelling design analysis considered the additional fishing information (AIS tracks). The analysis focussed on the east side of the development locations and further moorings design mitigation that would avoid or reduce potential displacement effects from the respective developments. The new analysis confirmed that with a further 50m reduction to the proposed moorings boundary to the east of both fish farms could be safely accommodated. It was also determined that it was possible to remove the NE corner of the Carradale North moorings boundary, and the SE corner of the Carradale South moorings boundary as further mitigation aimed at maintaining as much access as possible to the fish grounds to the east of the fish farms. Following the refined technical moorings analysis, the extent of the respective moorings’ areas for both development proposals have been further reduced to 0.410 km2, a reduction of 13% compared to moorings area presented in the planning applications. A comparison of the mooring areas for the current operational fish farms vs proposed development is presented below: Moorings area – current 120m pens Moorings area – proposed 160m pens Carradale North 0.330 km2 0.410 km2 Carradale South 0.405 km2 0.410 km2 We would estimate approximately 95% of the supplied AIS (fishing vessel) tracks are now out with the proposed mooring development areas and any potential displacement effect would be minor compared to the present baseline position, with two operational fish farms in place. A site plan showing the revised moorings areas for both development proposal with geo referenced AIS fishing vessel tracks is annexed to this response (Annex 1). This document should be treated as Confidential and be detached from this response as it contains commercially sensitive information on fishing grounds. An amended Moorings Technical Analysis Report is annexed as a separate document to this response (Annex 2). The report details the inputs and results from a full technical dynamic analysis for the revised pen and mooring system design, confirming compliance with applicable equipment design requirements. Page 18
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LDP2 format template Nov 2023 Operational Mitigation In addition to embedded design mitigation to prevent conflict with commercial fishing Mowi can also commit to a series of operational mitigation measures. 1. Following site installation, the installed mooring anchor coordinates will be shared with local fishing vessels/CFA and the relevant fisheries representative bodies to allow bottom trawling to be undertaken as close to the mooring infrastructure as safely possible. 2. If appropriate and subject to other navigational considerations and approvals Mowi is content to provide for enhanced navigational markers for the anchor locations to the east of the fish farms to develop a safe transit-trawling corridor past the sites. 3. Following installation, the majority of the area taken up by the mooring lines for each development proposal will still be accessible for static gear fishing with full exclusion only required during maintenance of mooring lines or boat operations. Mowi would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels within the mooring’s footprint of the development sites. 4. Mowi would be willing to work with the CFA to improve communications and liaison with local commercial fishing vessels on farming operations and activities (such as equipment installation) and to provide a mechanism whereby areas of conflict could be discussed and resolved. If deemed appropriate we would be willing to work with the planning authority to find suitable wording to capture this as a condition on any planning decisions. Conclusion Through a detailed and exhaustive design process for the mooring systems for each development, it has been possible to reduce the length of individual mooring lines to ensure the mooring areas have the minimum footprint. • The extent of the mooring’s areas presented in the planning applications were 0.471km2 for Carradale North, and similarly 0.471km2 for Carradale South. • Following the revised technical moorings analysis, the extent of the respective moorings’ areas have been reduced (from planning application details) to 0.410 km2 (13% reduction) for both proposed development sites (Carradale North and Carradale South fish farms). • While the focus of our attention has been developing embedded site design mitigation to allow continued access to fishing grounds and avoid (or reduce) displacement effects to commercial fishing there are also a number of operational mitigations measures we can implement to promote and facilitate fishing with and in close proximity to the site. In particular we would seek to build on the effective working relationship established through this process with the CFA and extend this to the establishment of better local engagement forums with commercial fishing interests in Kilbrannan Sound. We understand the frustration and concerns of commercial fishermen on spatial squeeze of accessible fishing grounds. Aquaculture has shared concerns on the threats of cumulating pressures on use of shared marine spaces, and we have tried to limit our use of the marine environment at Carradale to ensure we avoid (or minimise) the potential for displacement effects, supporting the principle of mutual co-existence with commercial fishermen. Next Steps It is intention to proceed with a formal amendment to the planning applications on to revise the mooring areas in accordance with the above. The requisite amended application forms and associated updated supporting information, including revised plans will be submitted in due course. Data limitations and uncertainties exist with regards to the available evidence on the frequency and scale of fishing activity adjacent to and Page 19
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LDP2 format template Nov 2023 within the development areas and the extent of any potential displacement effects. Accordingly, we are additionally considering the commission an independent desktop review to better characterise commercial fisheries within the proposed development site. The intention is to identify the key fisheries interests for a finer scale analysis and scope potential interactions with the proposed development infrastructure. Officer comment: revised plans have been submitted following the discussions with CFA and the results of the Technical Moorings Report. Update: The applicant has commissioned and submitted a further Commercial Fisheries Impact Assessment by Poseidon (October 2025) to assess the nature and level of fishing activity in the Kilbrannan Sound areas of the western arm of the lower Firth of Clyde; to examine the likely spatial and temporal impacts of the farms’ redevelopment on identified fishing activities; and to provide an independent impact assessment and suggest possible mitigation options. This report has concluded that the proposed site is located within the ICES rectangle 40E4 and around 10,600 t of mainly shellfish are landed from this area, worth some £25.6 million per annum over the c. 2,500 km2 of statistical rectangle 40E4. The proposed site’s combined mooring area is just 0.82 km2 and from analysis undertaken Based on AIS data records over a five year period (2019 – 2024) only nine (1.4%) were within the new proposed planning boundary and four (0.3%) were within the proposed mooring boundary. This suggests that the planning boundary is the effective westward limit of bottom trawling this side of the Kilbrannan Sound. This is around 300 m away from the outermost pens under the current configuration and 225 m from the outermost pens under the proposed configuration. Based on this evidence, the proposed move to the east will not have any significant impact on bottom trawling activities, although there will be very little margin for error in navigation. Although not confirmed, this is also likely to be the case for the smaller scallop dredging fishing in the same area. Although not verified by the AIS data (most creel boats do not have historical AIS track records but keep private plotter records and are now having to adopt i-VMS), crab and lobster creeling is likely to be located in the rocky, shallower water of the western inshore part of the site. Nephrops creeling could take 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 (see the two sections above), this is unlikely. Clyde Fishermen’s Association Response to Posiedon Report (14.11.2025): CFA reiterate that as the local fishing association with over 40 fishing boats in our membership, we represent the majority position of those vessels and their crew. We are extremely concerned the local and national socio-economic value of coastal fisheries and their onward benefits and place in the link of local economies is not well understood or downplayed. Most local fishermen in Argyll and Bute will emphasis a lot of safe and productive ground has been lost to aquaculture in recent years, and often they feel their businesses and perspectives are not being successfully fully heard. We note in the Poseidon report that a small percentage of local fishing area is to be impacted, however in a large marine area it is often the case that an area which is under 5% of the total area could be the most productive and safest, therefore using a mitigation metric in terms of percentage of total area lost really doesn’t make sense. It’s the productivity of that area and its safety which should be considered. Page 20
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LDP2 format template Nov 2023 Local fishermen met with MOWI some time ago and provided fishing tracks of their activity, some of which will be recorded on AIS and some which would not have been. The fishermen explained how important this area is to them in person, and the provided tracks clearly showing creep into important fishing grounds via the proposal. The local fishermen feel the current aquaculture site co-existing with local fishing in the area is already a compromise, but this change would be a step too far for loses for local fishing boats. We note that the Poseidon report acknowledges their report doesn’t capture vessels not using AIS, and this will represent a good number of local boats. The Scottish Government are currently looking at improved ways to monitor vessels to make sure all activity is captured and the monitoring systems we have are more effective. It is without dispute that those local vessels not using AIS won’t have been factored into this assessment at all, and so the assessment will be missing out vital detail for fishing. Had we a similar opportunity and resource to commission a similar style report for wild fishing we are sure it would show a very different picture in socio-economic terms. We also note that the time period landings and activity the Poseidon report covers the period of both Brexit redtape impacting catching and exporting of seafood and the covid period. During both of these events many fishing boats were forced to tie up or operate in a much reduced capacity due to domestic and international market shut down/reduction. Indeed for periods during this timescale fishermen needed government support via grants to survive as did many businesses. Whilst fishing was returning to some normality nearer the end of this period, it wouldn’t be fair to assess the socio- economics of this period on a typical metric for the fishing sector. The Poseidon doesn’t touch on the value of the landings into Northern Irish ports (around £45m total landings, some of which will be caught in the Clyde Marine Area). Cumulative issues are not considered in this report either. In the Marine Area of the Clyde we have 5 Marine Protected Areas, a weekend ban on mobile fishing, a seasonal closed cod box, Royal Navy closed areas, numerous aquaculture sites, No Take Zones and a number of energy cables particularly around Carradale, with more planned in the near future. In addition we are going to consultation shortly for Priority Marine Feature Closures and more Marine Projected Areas and rewilding projects. If we want to have a vibrant sustainable fishing fleet, the boats need space to fish, and locally this would unfortunately be another restriction they can ill afford. Death by a thousand small cuts for fishing shouldn’t be an option we choose if resilience and development is an option. We have good stock advice for the area and latent capacity in fishing which is also a socio-economic opportunity and potential for the area which shouldn’t be discounted. This year ICES advised a 54% increase in nephrops alone for the West Coast (21,654 tonnes), there is scope to develop fisheries not just in nephrops but beyond the currently fished stocks. Local Fishermen have set out a vision for development for fisheries in the area which can be found on the link below in short and long version: Science & Policy - Clyde Fishermen’s Trust We have also invested heavily in training courses and a training centre to service the whole Clyde area for fishing, and we are doing our best to boost the socio-economics of our local fishing sector by innovation and development, but we can only successfully achieve this well if fishing is resilient and reflexive, we cannot always be the losing party in respect to marine access, it will defeat the work fishermen from the Argyll and Bute region and the Clyde region beyond are investing into a better future. Page 21
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LDP2 format template Nov 2023 We also note the Poseidon report does not capture the onward value of fishing beyond. Fishing supports the crew on the boats and their families, but it also supports haulage, retail and hospitality domestically and internationally, processing and exporting, boatyards and engineers, fuel merchants, policy work, supermarkets and accreditation companies Officer comment: please see assessment of commercial fisheries impacts in Section 3 of the attached Appendix A - Committee Report. Argyll and Bute Biodiversity Officer (dated 08.11.24): No comments to make. Argyll and Bute Environmental Health (dated 4.9.24): No comments but notes that there may be a need to protect the amenity for nearby sensitive receptors in the locality of the development. Officer comment: The applicant has committed to mitigation measures to protect neighbouring amenity from operational noise and light and adherence to this will be secured by planning condition. (D) HISTORY: 09/00905/MFF Formation of new 14 cage fish farm including foodstore/service pontoon. (Approved 11.11.2009) 14/01047/MFF Alterations to existing marine fish farm by enlargement of mooring grid to increase cage spacing, without extension of mooring area or changes in number or size of cages (Approved 18.7.2014) 15/01939/MFF Re-equipment of marine fish farm from 14 no. 100 metre circumference cages to 10 no. 120 metre circumference cages and retention of feed barge (Approved 14.9.2015) 18/01174/SCRSCO Screening and scoping request for alterations to and extension of existing fin fish farm and increase in biomass from 2500 tonnes to 3750 tonnes (Opinion Issued 19.7.2018) 18/00263/PNMFF, Replacement of 400T fee barge with 650T feed barge at same location (No objection 28.2.2018) 19/00106/PNMFF SOUTH Installation of replacement pens and nets (PA Not required 26.7.2019) 23/00262/SCREEN SOUTH Screening Opinion for reconfiguration of infrastructure from 10 x 120m circumference cages to 6 x 160m circumference cages with a parallel minor relocation into deeper water (Negative Screening Opinion issued 6.4.2024) (E) PUBLICITY: ADVERT TYPE: Regulation 20 Advert Local Application EXPIRY DATE: 15.11.2024 Page 22
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LDP2 format template Nov 2023 (F) REPRESENTATIONS: (i) Representations received from: James Anderson, Office, 110 Sound Of Kintyre, Campbeltown, PA28 6GA A further 11 proforma objection letters have been submitted (please see Appendix B for a list of the contributors). Representations are published in full on the planning application file and are available to view via the Public Access section of the Council’s website. (ii) Summary of issues raised: • Impact on local fishermen and families • Better areas available for expansion • Concern about ability to influence planning decisions Officer response: the impact on commercial fisheries is considered in detail in Section 3 of the attached Committee Report – Appendix A. In summary, officers consider that the applicant has engaged proactively with the Clyde Fishermen’s Association from the inception of the proposed project and in response to concerns raised has commissioned detailed technical analysis to reduce the extent of the moorings area by 14%, with the intention of minimising the impact on the local fishing industry. The applicant has also proposed further operational mitigation measures and ongoing engagement in response to the CFA’s sustained objection. A planning condition has been applied to support the establishment of a local engagement/liaison forum and agree mechanisms for operational mitigation to support the principle of co-existence with the local commercial fishing activity in the Kilbrannan Sound. It is further noted that Argyll District Salmon Farming Board support the proposed change in fish cage size and configuration on the basis that the changes will include the use of the most robust modern cage technology and fish farm handling procedures. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report: ☐Yes ☒No (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: ☐Yes ☒No (iii) A Design or Design/Access statement: ☐Yes ☒No (iv) A Sustainability Checklist (with reference to the requirements of LDP2 Policy 04) ☐Yes ☒No (v) A report on the impact of the proposed development eg. Retail impact, transport ☒Yes ☐No Page 23
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LDP2 format template Nov 2023 impact, noise impact, flood risk, drainage impact etc: Planning Application: Overview (Supporting Document) including: Annex 1 Site Plans and Charts Annex 2 Equipment Plans and Elevations Annex 3 Equipment Attestation Annex 4 Containment and Escapes Contingency Plan and Moorings Technical Report Annex 5 Sea Lice Management, Efficacy and Attestation Annex 6 Waste Management Plans Annex 7 Predator Mitigation Plan Annex 8 Screening Opinion – EIA Not Required Annex 9 Seascape, Landscape and Visual Assessment (Munro Landscape (02.11.2023). Kilbrannan Sound Environmental Management Plan (February 2024) Post submission: Mowi Statement of Mitigation (12.9.2025) Mowi Socio-economic Supporting Statement (12.9.2025) Moorings Technical Analysis Report, Reference GFME-TR- 076, dated 18 February 2025 Commercial Fisheries impact assessment from a revised pen layout at the Carradale fish farm – Phase 1 Report – Desktop Evaluation (October 2025) (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: ☐Yes ☒No (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: ☐Yes ☒No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application (i) List of all Development Plan Policy considerations taken into account in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) Part 2 – National Planning Policy Sustainable Places NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 2 – Climate Mitigation and Adaption NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places Page 24
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LDP2 format template Nov 2023 NPF4 Policy 12 – Zero Waste Productive Places NPF4 Policy 25 – Community Wealth Building NPF4 Policy 29 – Rural Development NPF4 Policy 32 – Aquaculture Argyll and Bute Local Development Plan 2 (Adopted February 2024) Spatial and Settlement Strategy Policy 04 – Sustainable Development High Quality Places Policy 08 – Sustainable Siting Policy 14 – Bad Neighbour Development Diverse and Sustainable Economy Policy 28 – Supporting Sustainable Aquatic and Coastal Development Sustainable Communities Policy 59 – Water Quality and the Environment Policy 63 – Waste Related Development and Waste Management High Quality Environment Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 74 – Development Impact of Sites International and National Importance (ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 3/2013. • Third Party Representations • Consultation Reponses • Planning History • ABC Technical Note – Biodiversity (Feb 2017) • ABC Landscape Studies • Scotland’s National Marine Plan (2015) (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: ☒Yes ☐No The proposal is Schedule 2 development and a Negative Screening Opinion (ref: 23/00262/SCREEN) was issued by the Council on 6.4.2023. (L) Has the application been the subject of statutory pre-application consultation (PAC): ☐Yes ☒No (M) Does the Council have an interest in the site: ☐Yes ☒No (N) Requirement for a pre-determination hearing: ☐Yes ☒No Page 25
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LDP2 format template Nov 2023 In deciding whether to exercise the Council’s discretion to allow respondents to appear at a discretionary hearing, the following are of significance: • How up to date the Development Plan is, the relevance of the policies to the proposed development and whether the representations are on development plan policy grounds which have recently been considered through the development plan process. • The degree of local interest and controversy on material considerations together with the relative size of community affected set against the relative number of representations, and their provenance. The current Local Development Plan was approved in 2024. NPF4 which was approved in 2023 contains a similar criteria-based approach in relation to aquaculture applications. It is considered that the development plan is up to date. At the time of writing this application has attracted 11 objections from local fishing boat operators relating to conflict over fishing grounds. No objections have been raised by statutory consultees in relation to these matters. Furthermore, it is noted that the site is already in operation for marine fish farming and there will be no overall increase in biomass as a result of the proposed changes to pen sizes. Officers consider that the relocation of Carradale North and South represents a small percentage of the available fishing grounds and it is noted that through further discussions, revised moorings have further reduced the impact on local fishing activity. It is further noted that the modernisation of marine fish farming activity at this site is welcomed by statutory consultees for benefits to fish health and the applicant has committed to ongoing communication with local fishing boats to maintain access to dishing grounds wherever possible. It is not considered that there would be merit in holding a Pre-determination Hearing as all planning matters raised as objections have been suitably addressed through the submitted material and/or through the use of planning conditions. It is the view of officers that a pre- determination meeting therefore would not add value to the decision-making process in this instance. (O)(i) Key Constraints/Designations Affected by the Development: (ii) Soils - Not applicable as this is a marine development (iii) Woodland - Not applicable as this is a marine development (iv) Land Status / LDP Settlement Strategy - Not applicable as this is a marine development (P) Summary assessment and summary of determining issues and material considerations This application is for a change of equipment and minor relocation of an existing marine fish farm in the Kilbrannan Sound approximately 400m off the eastern shore of the Kintyre Penninsula. The proposal would replace the existing 10no 120m Page 26
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LDP2 format template Nov 2023 circumference pens with 6 x 160m pens in a formation of 3 x 2 along with the slight change in the position of an existing 650 tonne feed barge which would be located to the south of the group on the shore side. The site would continue to be serviced from the company’s existing shore base located at Carradale Harbour. The proposed development is located approximately 1.8 km north of Carradale village on the western edge of Kilbrannan Sound and east of the Kintyre peninsula. The smaller hamlet of Grogport lies approximately 2.6 km north west of the Site. There is to be no change to the consented biomass for the site. The proposal is part of a wider 5 year project by the applicant to upgrade and modernise fish farming pens to bring about a number of benefits: • Improved health and safety conditions through the upgrading of equipment; • Improved health and welfare of fish. • As the biomass is not increasing the density of the fish will be reduced and fish can be treated more efficiently in fewer pens, reducing amenity impacts. This proposal is not EIA Development. The recommendation on this application has been guided by the consultation responses from Scottish Government Marine Directorate, NatureScot, SEPA, Argyll District Salmon Fishery Board, Historic Environment Scotland, Northern Lighthouse Board, Royal Yachting Association, Argyll and Bute Environmental Health, and the Argyll and Bute Marine and Coastal Officer. Representations received have been addressed in Section F of this report (above) and against the planning policies of the adopted Development Plan which comprises NPF4 and LDP2 as well as other material considerations, including those relating to marine planning (see Appendix A). The proposal would accord with Development Plan policy and accordingly, it is recommended that planning permission be approved subject to conditions (Q) Is the proposal consistent with the Development Plan: ☒Yes ☐No (R) Reasons why Planning Permission or Planning Permission in Principle Should be Granted: The proposal is considered to be consistent with the relevant provisions of the Development Plan, and there are no other material considerations of sufficient significance to indicate that it would be appropriate to withhold planning permission having regard to s25 of the Act. (S) Reasoned justification for a departure to the provisions of the Development Plan Not Applicable (T) Need for notification to Scottish Ministers or Historic Environment Scotland: ☐Yes ☒No Page 27
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LDP2 format template Nov 2023 Author of Report: Shelley Gould Date: 1/12/25 Reviewing Officer: Sandra Davies Date: 1/12/25 Fergus Murray Head of Development & Economic Growth Page 28
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LDP2 format template Nov 2023 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 29
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LDP2 format template Nov 2023 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 30
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LDP2 format template Nov 2023 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 31
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LDP2 format template Nov 2023 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 the members of the Clyde Fisheries Association. 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. Page 32
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LDP2 format template Nov 2023 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 vessels as is reasonably practicable. Page 33
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LDP2 format template Nov 2023 ADDITIONAL NOTES TO APPLICANT • Please see the consultation response dated 18 October 2024 from the Northern Lighthouse Board (NLB) for the lighting and marking requirements for this site. • The Aquatic Animal Health (Scotland) Regulations 2009 requires the authorisation of all Aquaculture Production Businesses (APB's) in relation to animal health requirements for aquaculture animals and products thereof, and on the prevention and control of certain diseases in aquatic animals. The authorisation procedure is undertaken on behalf of the Scottish Ministers by the Fish Health Inspectorate (FHI) at the Marine Directorate Marine Laboratory. To apply for authorisation for an APB or to amend details of an existing APB or any site that an APB is authorised to operate at, you are advised to contact the FHI as follows: Fish Health Inspectorate, Marine Directorate Marine Laboratory, 375 Victoria Road, Aberdeen, AB11 9DB. Tel: 0131 244 3498; Email: ms.fishhealth@gov.scot • All marine farms, whether finfish, shellfish or algal, are required to apply for a marine licence under Part 4 of the Marine (Scotland) Act 2010. To apply for a marine licence, or to amend details of an existing marine licence (formally Coast Protection Act 1949 – Section 34 consent), please visit the Scottish Government’s website at http://www.gov.scot/Topics/marine/Licensing/marine/Applications where application forms and guidance can be found. Alternatively you can contact the Marine Directorate Licensing Operations Team (MD-LOT) by emailing MD.MarineLicensing@gov.scot; or calling 0300 244 5046. Page 34
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LDP2 format template Nov 2023 COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 24/01381/MFF PLANNING LAND USE AND POLICY ASSESSMENT 1. Introduction 1.1. The Carradale South fish farm was originally consented in 2009 with Carradale North being consented in 2015. This application is for a change of equipment for the existing Carradale South marine fish farm, located in the Kilbrannan Sound approximately 400m off the eastern shore of the Kintyre Penninsula. The proposal would replace the existing 10no 120m circumference pens with 6 x 160m pens in a formation of 3 x 2 along with the slight change in the position of an existing 650 tonne feed barge which would be located to the south of the group on the shore side. The site would continue to be serviced from the company’s existing shore base located at Carradale Harbour. 1.2. With innovation in pen design and with improving design and capacity of support vessels, Mowi has been upgrading pen equipment across Scotland since 2022. There are now 11 Mowi sites operating 160m pens in Scotland with the Carradale farms being the latest sites proposed to transition. The drivers for the developments are operational efficiencies and establishing the conditions for improved health and welfare of farm reared salmon. Fewer, larger pens will reduce stocking density (leading to fish health and welfare benefits) in addition to increasing the efficacy of administering any treatments and undertaking farm maintenance activities. No increase in fish production levels is being sought. The applicant has submitted several applications to the Council to upgrade operational fish farm facilities by replacing existing pens with few smaller pens. This allows a lower stocking density without increasing biomass and has associated benefits for health and safety and fish health. It is noted that there is no proposed increase to the biomass for this site which is 2500 tonnes as consented through the CARs license. A sister application has been submitted for the adjacent Carradale North Marine Fish Farm (24/01382/MFF). The applicant has also recently received planning permission to improve shore base facilities at Carradale Harbour (25/00884/PP) as part of a wider generation proposal for the area. 1.3. The proposed development is located approximately 1.8 km north of Carradale village on the western edge of Kilbrannan Sound and east of the Kintyre peninsula. The smaller hamlet of Grogport lies approximately 2.6 km north west of the Site. The site is not located within any areas of local or national designation and is 2.5km from the east Kintyre Local Landscape Area. 2. Planning Policy 2.1. The Development Plan for the determination of this planning application comprises National Planning Framework 4 (NPF4), adopted February 2023, and the Argyll and Bute Local Development Plan 2, adopted February 2024. NPF 4 is based around six overarching spatial principles which the proposed development should align with. These are: • Just transition; • Conserving and recycling assets; • Local living; • Compact urban growth; Page 35
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LDP2 format template Nov 2023 • Rebalanced development; • Rural revitalisation. 2.2. Not all of these principles will be relevant to every development and in relation to the current proposal it is considered that just transition, rural revitalisation, local living and rebalanced development would apply. In terms of rural revitalisation, NPF4 supports development that helps retain and increase the population of rural areas in Scotland. 2.3. The main policy which relates to aquaculture in NPF 4 is Policy 32, however, other policies within this plan are also relevant and need to be considered in the determination of this proposal. With regard to LDP2, Policy 28 is the main aquaculture policy, however, there are also other relevant policies which are listed above against which the proposal requires to be assessed. 2.4. The proposal benefits from general support from the Scottish Government’s National Marine Plan and from NPF4 which together recognise the contribution of the aquaculture sector to the rural economy and which seek to support sustainable economic development. The National Marine Plan and NPF4 both support marine fish farming where it can take place in environmentally sustainable locations, where it does not exceed the carrying capacity of the water body within which it is to be located, and where it does not give rise to significant adverse effects upon nature conservation, wild fish, historic environment or other commercial or recreational water users. 2.5. Whilst not part of the Development Plan, the Council as a public body is required to take authorisation decisions in accordance with the National Marine Plan (NMP) as the proposal extends into the marine environment, unless relevant considerations indicate otherwise. The proposal should be consistent with general policies of the NMP including: GEN 1 – General planning principle; GEN2 – Economic benefit; GEN 3 – Social benefit; GEN 4 – Co-existence – requires consideration that may occur and the likely effect of interaction between inshore commercial fisheries (loss of fishing ground) and marine and coastal recreational activities. GEN 5 Climate change; GEN7 – Landscape/seascape; GEN 9 – Natural Heritage GEN 10 – Invasive non-native species; GEN 11 – Marine Litter; GEN 12 – Water Quality and Resource; GEN 13 – Noise. 2.6. NPF4 Policy 32 refers the National and Regional Marine Plan and notes that proposals will be supported where they comply with the relevant plans. The criteria noted within the NMP policies above are also covered within the Development Plan policies. 2.7. Beyond development plan considerations, in determining the application regard has to be had to the Council’s Economic Development Action Plan which identifies aquaculture as an important contributor to the local economy, and to national government economic and sectoral policy, the stated intention of which is to seek to expand the finfish sector substantially to meet internal and export demands and to help sustain direct and indirect employment in rural areas. Page 36
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LDP2 format template Nov 2023 2.8. In addition, one of the proposals contained within the Rural Growth Deal for Argyll and Bute relates to a vision for Argyll and Bute to be the leading region for innovation in marine aquaculture in Scotland, UK and globally, by underpinning sustainable, inclusive business growth through investment in world class marine science and technology. This includes a commitment to a Marine Industry Needs Assessment. This study will provide the evidence base for industry needs to inform future investment outcomes and the potential options available to deliver these outcomes. This will assist in identifying the key priorities for Rural Growth Deal investment and where this should be targeted to support sustainable growth of this sector and set out in the business case for consideration and approval by Scottish Government. 3. Assessment Against Policy Criteria 3.1. NPF Policy 32 relates specifically to aquaculture. It aims to encourage, promote and facilitate aquaculture development whilst minimising adverse effects on the environment. The policy outcomes sought from this policy are: • new aquaculture development is in locations that reflect industry needs and considers environmental impacts; • producers will contribute to communities and local economies; • prosperous finfish, shellfish and seaweed sectors; • migratory fish species are safeguarded. 3.2. In terms of the spatial strategy Policy 32 does not support development in the north and east coast of mainland Scotland. This is in order to safeguard migratory fish species. 3.3. Point (C) of Policy 32 requires consideration of the operational impacts of fish farms and specifically cites a number of criteria which require to be considered. These criteria are also reflected in the Council’s LDP2 which was adopted in February 2024. 3.4. The proposal requires to be assessed against all of the relevant policies contained within the development plan and not just the aquaculture specific ones. There are some parallels between the requirements of the aquaculture policies and other policies within the development plan and these will be highlighted in the assessment of this application. The application will be assessed against the criteria from LDP2 Policy 28 below with other relevant policies from NPF4 and LDP2 referred to where they would apply. Landscape / coastal character, seascape or visual amenity (including Isolated Coast, Wild Land and National Scenic Areas) 3.5. The applicant has submitted a Landscape, Seascape, Visual Impact Assessment for the Carradale Fish Farm Proposed Replacement Pens carried out by Munro Landscape (02.11.2023). The appraisal evaluates the landscape and visual effects the proposed modifications to the Carradale North and Carradale South sites to replace the 20 existing 120m circumference fish pens with 12 160m circumference fish pens with a slight relocation to the east towards deeper water which will see the Carradale North pen grid move approximately 129m and Carradale South move 149m. The Proposed Development would be located within Seascape Character Area 10 - Lower Firth of Clyde (west) and adjacent to the Upland Forest Moor Mosaic Landscape Character Type. The baseline studies confirmed that the Proposed Development would not be located within a designated landscape however the North Arran NSA is located 2.7 km to the east and the East Kintyre APQ lies 2.0 km to the south of the proposed location. Page 37
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LDP2 format template Nov 2023 3.6. The appraisal provides a comparative Zone of Theoretical Visibility (ZTV) illustrating the ‘change’ in visibility resulting from the change in the location of the pens. Within 5 km of the Proposed Development the ZTVs indicates a very narrow band of visibility on Kintyre, with views largely constrained to the eastern slopes and shoreline. Notable locations/receptors with theoretical visibility include the village of Carradale, and the B842 between Cour and Grogport. Visibility is also predicted from short sections of the Kintyre Way and from the summit of Cnoc nan Gabhar (Deer Hill). To the east, from landfall locations on Arran, visibility is indicated as occurring from the coastline and western slopes of the island, notably between Imachar and Whitefarland Point (including the C147 and Arran Coastal Way). Open views from offshore locations across the study area within the Kilbrannan Sound are indicated as occurring. These views of the Proposed Development are predicted to be very similar in extent to the existing Carradale North and South Fish Farms and add only very small areas of new visibility of the fish pens. 3.7. The submitted SLVIA concludes that resulting effects on landscape character associated with the replacement, and minor relocation of the fish pens would result in, at most, negligible effects on the character of the seascape and landscape. These effects are not significant and ultimately reversible. There would also be no significant effects on landscape designations within the study area to the Proposed Development, including the North Arran NSA and the East Kintyre APQ. Effects on all designations within the study area resulting from the Proposed Development would be at most negligible. These effects are ultimately reversible. The SLVIA concludes: During the operational phase there would be no direct effects on landscape features or elements which define landscape character types or contribute to the special qualities of landscape designations. All effects on landscape character types and designations would be indirect and non-significant in nature only, the assessment determining that in comparison with the existing fish pens the level of effect would be negligible. The level of effect on Lower Firth of Clyde (west) SCA would also be negligible.” 3.8. In terms of visual effects, 5 viewpoints were selected to aid the assessment of this issue. The viewpoints and the reason for their selection are noted in the table below: View point number Viewpoint Name Reason for selection Distance to the Proposed Development 1 B842 north of Grogport The viewpoint is representative of the views available for road users of the B842 road, and cyclists on the NCR 78, north of Grogport, at a promoted picnic are within the Plateau Moor and Forest LCT 39, and the Port Raoin Mhor to Sgeir Bhuidhe Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. 3km 2 Cnoc nan Gabhar (Deer Hill) The viewpoint is representative of the views available for recreational receptors at a hill top location, within the Plateau Moor and Forest LCT 39. 1.9km 3 Culcreuch Road, Carradale The viewpoint is representative of the views available for residential 2.2 km Page 38
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LDP2 format template Nov 2023 receptors, on Culcreuch Road, Carradale within the Coastal Glens LCT 36, and the Port na Cuile to Port Raoin Mhor Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the Area of Panoramic Quality (LLA). 4 Carradale Harbour The viewpoint is representative of the views available for recreational receptors at Port Crannaich, Carradale Pier, within the Coastal Glens LCT 36, and the Port na Cuile to Port Raoin Mhor Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the Area of Panoramic Quality (LLA). 2.2km 5 Imachar Point, Arran The viewpoint is representative of the views available for recreational receptors on the Arran Coastal Way, south of Imachar, within the Raised Beach Coast and Cliffs LCT 59, and the Loch Ranza to South Machrie Bay Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the North Arran National Scenic Area and Special Landscape Area. 4.7km 3.9. In consideration of the degree of change to the existing view that the Proposed Development would constitute the predicted magnitude of change arising from the Proposed Development would be negligible. The visual effects on visual amenity experienced by people in Carradale would be negligible, non-significant, long-term (reversible) and adverse. 3.10. Visual impacts on tourists, or those participating in recreation activities, may be brief in nature by passing through the area on boat, ferry, horse, foot, bike or kayak, their sensitivity to landscape and visual change is high because their purpose/activity is to appreciate landscape and surroundings. The visual assessment has considered views from recreational receptors within 10 km of the Development focusing on those within 5 km radius of the Proposed Development within the detailed study area. Nearby recreation receptors within the detailed study area of the Development include the National Cycle Route NCN 78 and the Kintyre Way long distance footpath on Kintyre. On Arran, the Arran Coastal Way falls within the detailed study area where it passes close to Imachar. Page 39
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LDP2 format template Nov 2023 3.11. The visual assessment has also considered the potential visual effects likely to be experienced by people travelling through the landscape on the local road network. Views will vary depending on proximity to the road, the mode of transport, the angle of view, and intervening landscape features. Potential visual receptors falling within the detailed study area included residents, including those in the village of Carradale and the hamlet of Grogport, in addition to users of the B842 on Kintyre and C147 on the Isle of Arran. Recreational routes falling within the study area include the Kintyre Way, the Arran Coastal Way and National Cycle Route 78. A number of core paths were also identified, these principally comprising a network of paths around Carradale but also forming sections of the Kintyre Way or following the B842. There are also a number of Core Paths within the Study Area, and the following have been identified as wholly or partially falling within the detailed study area: • C094(b) – Tayinloan – Carradale East West Link; • C093(b) - Carradale Forest circular; • C403 - Port na Cuile - Seneval Wood, Carradale; • C097(b) - Carradale Bay circular; • C088(c) - Campbeltown to Cloanaig • AR81 – Coirein Lochan. 3.12. For visual receptors, the Proposed Development, predominantly as a result of the very minor relocation of the pens to the east but also as a result of changes to the size and number of pens, would very slightly change the views people experience. In comparison to the views of the existing pens, the Proposed Development would result in a negligible effect in views from Carradale and no effect from Grogport. In views from transport and recreational routes, both on Kintyre and the Isle of Arran, the Proposed Development would similarly result in a negligible effect on visual amenity. In all cases these effects would be non-significant and reversible. 3.13. In conclusion, there would be no significant seascape, landscape effects and visual effects arising as a result of the Proposed Development in comparison to the degree of change associated with the replacement pens and the existing fish pens to Carradale North and South. It is concluded that the Proposed Development would not result in significant effects on landscape / seascape character and visual amenity. 3.14. The proposal would therefore be in accordance with aquaculture policies 32 d (i) (NPF4), Policy 28 – Supporting Sustainable Aquatic and Coastal Development, LDP2 Policy 4 – Sustainable Development and LDP2 Policy 8 – Sustainable Siting. The natural, built and / or historic or archaeological sites and their settings 3.15. In terms of Marine Cultural Heritage, Historic Environment Scotland has confirmed there are no marine or terrestrial heritage assets within their statutory remit within the development site boundary or within its vicinity 3.16. In addition to policy 28 of LDP2 this would also accord with LDP2 policies 15 and 19. This element of the proposal would also accord with NPF 4 policies 7 and 32. Designated sites, habitats and species for nature conservation (including Priority Marine Features, wild migratory salmonids and European Protected Species). 3.17. Policy 4 of NPF4 Natural Places seeks to ensure that Natural Places are protected and restored. This policy specifically refers to European sites. LDP2 polices 73 and 74 are relevant to this proposal. Policy 73 relates to development impact on habitats, species and biodiversity while Policy 74 relates specifically to sites of international importance. Page 40
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LDP2 format template Nov 2023 The aquaculture specific policies within NPF4 (policy 32) and LDP2 (Policy 28) also require consideration of these issues. 3.18. The proposal is not located within any nationally designated sites. However, reducing the impact of sea lice on wild migratory salmonids is a key element of the current Kilbrannan Sound Environment Management Plan (EMP) secured under the extant consent (20/01345/MFF) and the submitted documentation sets out a number of commitments by the applicant to manage sea lice impacts as follows: • Mowi is committed to compliance with the on-farm sea lice management threshold levels and set out in the Industry Code of Good Practice. This is achieved by applying strategic treatments / interventions, aimed at minimising the numbers of sea lice on farmed fish, and prioritising control during the wild smolt migration period. Mowi’s sea lice intervention strategy is based on the early (within 7 days) treatment of the very first individual pens rather than the later treatment of whole farms. • Mowi will manage its farms in the EMP Management Area in accordance with the Statement of Operational Practice as set in Annex B to minimise the impact of farming activity on wild salmonids. • Within EMP Management Area all three fish farms will be stocked synchronously with Atlantic salmon smolts. 3.19. Impacts on wild migratory salmonids are further managed through the provisions in the current EMP which sets out a wild fish monitoring strategy for the wild salmonid populations in Carradale Water and Endrick Water, under the direction of the Argyll Fisheries Trust and the Argyll District Salmon Fisheries Board. This strategy aims to produce data on the health of wild salmonid populations, within a zone of thirty kilometres from the fish farms located in the EMP Management Area and assess the available nursery habitat utilisation and levels of recruitment of juvenile salmonid fish in the middle and upper reaches of the Endrick Water (from Craigbell weir to Loup of Fintry). 3.20. As part of the wild fish monitoring programme for Carradale Water, Argyll Fisheries Trust undertook fish population surveys at seven sites in Autumn 2023 to assess the status of juvenile salmon and trout populations. These surveys update a time-series of data collected in 2005 and 2009, with proposed annual monitoring to develop a longer- term data set on the health of juvenile salmonid populations in the waterbody. The EMP monitoring has continued in 2025 at the locations shown below, and is completed annually, under the agreed monitoring plan with findings to be shared with the Council in line with the EMP once available: • Carradale Water Estuary - Sea Lice Monitoring • Fish Population Survey - Carradale, Glen Lussa, Machrie Water • Endrick-Blane Water - Electrofishing • Clyde Estuary - sea lice monitoring in the Clyde Estuary at Dumbarton 3.21. Mowi has also developed a sea lice connectivity model for the EMP Management Area and wider waters to simulate the distribution of farm derived sea lice to inform farm to farm infection risk and adaptive implementation of sea lice interventions. This modelling will help to gain a better understanding of the areas where wild salmonids may be vulnerable to infection pressure and inform monitoring locations. Mowi will also support appropriately designed acoustic tracking studies with the aim of addressing information gaps associated with the migration of salmon smolts. 3.22. These programmes are likely to be continued through any National Sea Lice Monitoring Framework to be implemented by SEPA. Page 41
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LDP2 format template Nov 2023 3.23. In accordance with the Predator Control Plan, observations of wildlife and interactions with the fish farm, including entanglement events, will be recorded and reported to Council and NatureScot every 6 months. Acoustic Deterrent Devices (ADDs) have the potential to disturb cetaceans, however, the applicant has committed to not using ADDs and this application has been assessed on this basis. A condition is proposed preventing the use of ADDs. 3.24. The proposal would accord with LDP2 Policy 73 – Development impact on Habitats, Species and Biodiversity and LDP2 Policy 4 – Sustainable Development due to the proposed mitigation for sea lice and the commitment to undertake wild fish monitoring and adaptive management if required. Biodiversity enhancement 3.25. NPF 4, Policy 3 – Biodiversity requires developments to contribute positively to biodiversity enhancement. Given the nature and land ownership constraints of marine fish farming operations, it is not always feasible to provide direct on-site benefits. However, in this instance, the applicant is considering additional biodiversity enhancement which may implemented as part of the Carradale Shorebase landscape and biodiversity enhancement strategy. The applicant is also collating a portfolio of biodiversity enhancement projects across Scotland (including native tree plantation on Skye and projects to improve smolt survival in the River Awe catchment). 3.26. A condition is proposed requiring an update to be submitted on these projects, to the satisfaction of the planning authority. Taking account of the above, it is considered that the proposal would also accord with NPF4 Policy 3 relating to biodiversity enhancement. Ecological status of coastal and transitional water bodies and biological carrying capacity (water quality & seabed impacts). 3.27. The site is operating with a CAR license (SEPA reference: CAR/L/1131788) and SEPA has confirmed no objection to the proposed changes to the operation of this site. Following the submission of further information, SGMD have advised that they have no objection to the proposals and there is no requirement for any further assessment regarding impacts to the water column regarding water column impact. 3.28. Subject to compliance with SEPA’s requirements it is considered that the proposal would comply with Policy 59 – Water Quality and the Environment. Commercial and recreational activity (including other coastal/marine users (MOD)), and navigational interests (including anchorages). 3.29. With regards to anchorages, The Royal Yacht Association (YHA) advised they have no objections to the proposal. As such it is concluded that there would be minimal impacts on recreational marine vessels within the local area. The proposal will not present adverse navigational safety issues, subject to navigational marking to satisfy Northern Lighthouse Board requirements and an informative has been attached to secure this. 3.30. With regards to the impact on commercial fisheries, there have been 11 objections submitted by local fishermen and a sustained objection by The Clyde Fishermen’s’ Page 42
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LDP2 format template Nov 2023 Association which is the membership body for 40 commercial fishing vessels within the Clyde. This sustained objection is despite ongoing dialogue between the applicant and the CFA (please see all representations provided in full in the Report of Handling Section C), the submission of a Moorings Technical Analysis Report, subsequent changes to reduce the proposed mooring area and the submission of a commercial fisheries impact report. 3.31. In terms of the impact of local fishing boats to access local fishing grounds, further moorings design modelling was undertaken by the applicant which subsequently confirmed the ability to reduce the indicative moorings boundary by 250m on the deep water, eastwards side. In addition, the moorings boundary to the west of Carradale south was adjusted eastwards by 56m, to facilitate improved access for creel fishermen (in response to concerns raised by the CFA) on the inshore side of the fish farm. The total development area (including moorings) for the original proposals subject to screening, was 0.826km2 for Carradale North, and 0.818km2 for Carradale South. Following consultation and the above revised technical moorings analysis, revised plans have been submitted which reduce the extend of the mooring areas to 0.471km2 for Carradale North, and 0.471km2 for Carradale South. A reduction of 13% compared to moorings area presented in the originally submitted planning applications and approximately 95% of the supplied AIS (fishing vessel) tracks are now out with the proposed mooring development areas. The applicant notes that any potential displacement effect would be minor compared to the present baseline position, with two operational fish farms in place. 3.32. In addition to developing embedded site design mitigation to allow continued access to fishing grounds and avoid (or reduce) displacement effects to commercial fishing the applicant has committed to a number of operational mitigation measures to prevent conflict with commercial fishing and to promote and facilitate fishing with and in close proximity to the site: • Following site installation, the installed mooring anchor coordinates will be shared with local fishing vessels/CFA and the relevant fisheries representative bodies to allow bottom trawling to be undertaken as close to the mooring infrastructure as safely possible. • If appropriate and subject to other navigational considerations and approvals Mowi is content to provide for enhanced navigational markers for the anchor locations to the east of the fish farms to develop a safe transit-trawling corridor past the sites. • Following installation, the majority of the area taken up by the mooring lines for each development proposal will still be accessible for static gear fishing with full exclusion only required during maintenance of mooring lines or boat operations. Mowi would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels within the mooring’s footprint of the development sites. • Mowi would be willing to work with the CFA to improve communications and liaison with local commercial fishing vessels on farming operations and activities (such as equipment installation) and to provide a mechanism whereby areas of conflict could be discussed and resolved. 3.33. To inform future discussions, the applicant has commissioned a Commercial fisheries impact assessment from a revised pen layout at the Carradale fish farm Phase 1 Report – Desktop Evaluation (October 2025). This Phase 1 report uses published information and AIS records to characterise commercial fisheries in the project area in order to identify and scope potential interactions with the farm infrastructure and operations. The report finds that the proposed farm location is located just north of Carradale on the western side of the Kilbrannan Sound within ICES rectangle 40E414. It is fished by vessels from two Page 43
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LDP2 format template Nov 2023 Scottish fisheries districts of Ayr and Campbeltown, landing mainly into Tarbert, Carradale, West Loch Tarbert and Troon & Saltcoats. The site bathymetry varies from 66 m to 96 m (Carradale North) and 28 m to 51 m (Carradale South), with the deepest parts of the site to the east. The main farm area appears to lie on an area of gravelly sand. Outside the site, the substrate turns muddier in the deeper water to the east. Around 10,600 t of mainly shellfish are landed from the ICES rectangle 40E4, worth some £25.6 million per annum. This is characterised as follows: • Demersal trawls (691 t): Nephrops dominates (>99%) the catch. These trawl caught Nephrops are mostly landed into Tarbet (255 t), Campbeltown (157 t) and Troon and Saltcoats (139 t); this catch is worth around £4 million. There is a very small catch of the bottom trawled finfish into Tarbert only. • Dredges (178 t): The dredge fishery caught 178 t of scallops in 2023. This is mainly landed in the West Loch Tarbert (96 t), Tarbet (35 t), Campbeltown (25 t) and Carradale (22 t). There are also 46 t of scallops landed into Tarbert from passive gears (apart from creels). • Pots and traps (e.g. creels) (191 t): Nephrops are the major creel-caught species, representing 71% of the catch of this passive gear type. Other target species of creels are brown crab (C. pagarus; 9% of the creel catch), velvet crabs (7%) and lobsters (also 6%). Creel-caught Nephrops are mainly landed into Tarbert (90 t), with 18 t each being landed into Carradale and Campbeltown. 3.34. It should be noted that these figures cover the c. 2,500 km2 of statistical rectangle 40E4 which is bisected by the Kintyre Peninsula, with the eastern side including Kilbrannan Sound to the south and Loch Fyne to the north and that the proposed site’s combined mooring area is just 0.82 km2. In terms of timing, the Nephrops caught by trawl peaks over the summer but the creel fisheries are more evenly spread through the year. The crab and lobster creel fishers tend to land during the second half of the year. Scallops are landed mainly in late summer. 3.35. A vessel activity analysis using mainly AIS data indicates that the proposed site extension is right on the western edge of the mainly north / south (and vice versa) tows of the bottom trawl fishery that extends eastwards across the Kilbrannan Sound. Based on AIS data records over a five year period (2019 – 2024) only nine (1.4%) were within the new proposed planning boundary and four (0.3%) were within the proposed mooring boundary. This suggests that the planning boundary is the effective westward limit of bottom trawling this side of the Kilbrannan Sound. This is around 300 m away from the outermost pens under the current configuration and 225 m from the outermost pens under the proposed configuration. 3.36. The report concludes that the proposed move to the east will not have any significant impact on bottom trawling activities, although there will be very little margin for error in navigation. Although not confirmed, this is also likely to be the case for the smaller scallop dredging fishing in the same area. As most creel boats do not have historical AIS track records but keep private plotter records, crab and lobster creeling is likely to be located in the rocky, shallower water of the western inshore part of the site. Nephrops creeling could take 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. 3.37. The report identifies that further work would need to be conducted to verify these results and where necessary establish the extent of the use of mobile gear to the east of the site (esp. smaller vessels that might not use AIS) and creeling activity in and around the proposed project site. Potential stakeholder groups are identified as the CFA, the Page 44
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LDP2 format template Nov 2023 Scottish Creel Fishermen’s Federation (SCFF) and possibly the West Coast Inshore Fisheries Group. 3.38. The CFA have responded to the commercial fisheries report. They note that with regards to the reduced mooring area achieved through revisions, the relative productivity of even a small area of fishing ground is the most important factor. They also note that the report does not adequately consider the wider economic impacts of the creeling industry to the UK economy. The CFA reiterate their frustration at ‘always being the losing side’ when it comes to sharing marine spaces with other parts of the aquaculture industry. However, it is noted in this occasion that the applicant has engaged comprehensively with the CFA, conducted extensive additional analysis with the intention of minimising this conflict as far as possible by avoiding or minimising potential for conflicts through revised mooring extents and have proposed further operational mitigation measures and ongoing engagement. 3.39. To this end, it is considered that a reasonable compromise on the reduced physical extent of the moorings - grounded in the analysis of the technical moorings report and the commercial fisheries study analysis has been reached and despite the ongoing objection, this is acceptable in terms of maintaining co-existence with an already consented marine fish farm. Planning conditions have been agreed with the CFA and the applicant to secure the operational mitigation and support the establishment of local engagement forums with commercial fishing interests in Kilbrannan Sound to support the principle of co-existence with the local commercial fishing activity. 3.40. Taking account of the above, it is considered that proposal would accord with NPF4 policy 32 and LDP2 Policy 28 where they refer to impacts on other marine users. Amenity, arising from operational effects (waste, noise, light and odour). 3.41. Impacts from marine aquaculture developments can include nuisance and disturbance for local residents, recreational and marine users from lighting, noise and odour associated with the installation and operation of fish farms. The applicant has provided details of proposed mitigation measures (submitted statement: ‘Mitigation of amenity impacts arising from operational effects’ September 2025) that will avoid or reduce potential noise, lighting and odour impacts. These measures are part of the project design (embedded mitigation) and good practice operational measures that would form part of standard planning conditions for any fish farm development. Managing noise impacts 3.42. With regard to noise, the development is located along a section of coastline which is sparsely populated, apart from the village of Carradale which is located 1.8km to the south. It is noted that the operational activity at Carradale Harbour is an existing contributor to background noise levels for residential receptors. 3.43. Implementation of best operational practice measures will eliminate, reduce, or manage any potential noise impacts from operational activities to levels within the limits of background noise, and ensure that they are minimised to ensure there are no likely significant effects from noise disturbance. Embedded project design and best practice management measures include the use of noise insulation on equipment, particularly on the feed barge, and restriction of operational activity to normal operational hours, as far as practicable. 3.44. A number of vessels will continue to support day-to-day operations at the farm throughout various stages of the production cycle. The vessels will undertake routine Page 45
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LDP2 format template Nov 2023 husbandry and maintenance activities, including grading, administering treatments, and harvesting. The reduction in pen units from 20 to 12 that will arise (across the combined fish farm) from the planned developments will result in operational efficiencies. Fewer pen units will require much less overall maintenance, such as net cleaning activity and fewer pen units will also allow the whole farm to be treated in quicker timelines. Overall it is anticipated that there will be a reduction in vessel traffic around the sites and associated activities such as net cleaning which have a noise profile. 3.45. It should be noted that although standard working hours are from 07:00 to 20:00 over 7 days, some operations may be required outside this period for reasons of fish health and welfare. Operations may also need to be undertaken outside of standard working hours due to tidal conditions at the site or as a result of delays caused by poor weather (due to the limited windows in which smolts require to be transported and transferred). Also, during certain periods of the year equipment integral to the production cycle will be required to run overnight (e.g. underwater lighting and aeriation systems). Planning conditions are attached to mitigate the effects of all out of hours operations and ‘Well Boat’ activity and further detail is set out below. Minimising light pollution 3.46. The three main operational light sources are (1) underwater anti-maturation lights placed into pens, (2) night-time operations, particularly involving ‘Well Boats’, and (3) measures set out by NLB to ensure the proposed development is appropriately marked, including navigational lighting. 3.47. At certain times of the fish growth cycle underwater lighting in pens is required for the purposes of preventing salmon maturation. Their window of use is from October to the end of the following March. As they are placed at depth surface glare is limited. Embedded design mitigation includes the use of low intensity lights, their correct downward orientation and shielding to reduce upward surface glare. 3.48. The applicant notes that to manage responsibilities for fish health and welfare it is sometimes necessary to employ ‘Well Boats’ in a 24/7 operation at the site. However, every effort is made during treatment planning and scheduling to minimise treatment times and avoid evening working periods especially in locations with neighbouring sensitivities. Where multiple pens require treatment, ‘Well Boat’ duration at a site can increase. As a result, in winter, with reduced daylight hours it is not always possible to avoid working during the hours of darkness and the use of lighting on these vessels. The applicant recognises this can introduce potential conflict with light sensitive properties nearby and has worked with ‘Well Boat’ operators to apply the following mitigation strategies to avoid the potential for light nuisance from essential night time operations (As per ‘Further supporting information’ Mitigation of amenity impacts arising from operational effects submitted 12.9.2025): • Design and scheduling (where possible) of ‘Well Boat’ based treatments with the aim of avoiding or reducing the frequency and duration of vessel treatment activity on site extending beyond 8pm. • Positioning of ‘Well Boats’ on site, to avoid the pen working area between the vessel and the shore (where practicable). • Reduction in intensity of lighting to minimum specifications required. • Application of shielding/covers to lights to avoid directional glare away from the working area. • Switching off lights when not required, for instance for the duration of treatments once fish have been loaded on the vessel. Page 46
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LDP2 format template Nov 2023 • Education, working with operators to understand light sensitive areas and the need for operational efficiencies in use of lights and positioning of the vessel. • Review and identification of options for temporary, less sensitive, positioning locations for ‘Well Boats’ away from farms once fish have been loaded for treatment. 3.49. Navigational Lights and Marks are prescribed by the International Association of Lighthouse Authorities, who class the navigational light (Special Mark) currently on site as ‘minor lights’ with a nominal range of 2 nautical miles. The Northern Lighthouse Board have advised they would require an additional Special Mark for the proposed development, so that the outer corner of the pen moorings grid is indicated. These lights flash yellow once every 5 seconds (off more than on). The feed barge displays an all- round white light (this is the same light that a vessel at anchor must display). While navigation lights are essential for safe navigation mitigations strategies to avoid potential nuisances, include proper placement, maintenance, shielding and education on their requirement with marine and local stakeholders. Odour & waste management 3.50. With regard to waste, a Fish Waste Management Plan (July 2024) is currently in place for the Carradale site and will remain in place. This contains provisions to ensure the development will be kept tidy and any rubbish found on the adjacent shoreline is collected on a regular basis to minimise the impacts of marine litter. 3.51. Odours from fish farms are generally associated with fish feed and storage of mortalities. Feed will be stored within sealed silos inside the proposed feed barge negating the risk of fugitive emissions associated with feed storage. Fish mortalities will be collected in a cone located at the bottom of each pen and retrieved using an integrated lift-up system. Site staff will aim to remove mortalities from the base of the pen on a daily basis and three times a week as a minimum. Stock mortalities removed from the pens will be stored in sealed containers for disposal at a licensed facility. There will be no net increase in overall biomass as part of the proposed developments arising and no increase in volume of waste produced is anticipated. There will be no material change to existing processes dealing with mortality disposal in the farm management area. This is consistent with NPF4 Policy 12 and LDP2 Policy 63. 3.52. In relation to well boat operations, the applicant has agreed to provide proactive notification of fish movements (i.e. delivery and collection of smolts) to the Council a year in advance to facilitate monitoring of any amenity impacts. This will be secured by planning condition. It is acknowledged that the tidal nature of this site is a limiting factor and may along with instances or poor weather, occasionally result in well boat use out of normal operating hours. However, it is best operational practice to ensure fish loading and harvesting happens during daylight hours to minimise amenity impacts as far as practicable. 3.53. It is considered that the impacts on amenity would be acceptable and would not conflict with LDP2 Policy 14 – Bad Neighbour Development, NPF 4 Policy 32 or LDP2 Policy 28. LPD2 Policy 29 – Existing Fish Farm Consolidation and Rationalisation requires that redundant equipment be removed from sites to manage waste impacts. A condition is therefore proposed to this effect. Net economic impact, including local community socio-economic benefits such as employment, associated business and supply chain opportunities. 3.54. NPF4 identifies the significant contribution aquaculture makes to the Scottish economy, particularly for coastal and island communities. It also recognises that changes Page 47
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LDP2 format template Nov 2023 in economic activity have potentially greater impacts on communities in rural Scotland than more populated areas. The applicant has submitted further information which details how Mowi Scotland activity supports Scotland’s rural employment levels which allows traditional settlement patterns and land use activities to be maintained and helps to sustain local rural services. 3.55. It is further noted by the applicant that Fish farming is uniquely placed to deliver actions that will contribute to Argyll and Bute Council’s Economic Strategy and the focus areas of People, Place, Planet and Prosperity with the company’s Argyll based operations contributing to social and economic objectives. Examples showing how we are contributing to social and economic benefits to the Kintyre peninsula are provided throughout this response, including the following: • An existing community fund is in place for the operation of the Carradale Fish Farms with Mowi contributing on an annual basis. • Mowi, in partnership with Salmon Scotland and other farming companies, are working with UHI Argyll to develop and deliver an Aquaculture SCQF4 academic qualification with the practical classroom base elements to be delivered in Campbeltown, Lochgilphead and Oban High Schools. Afterwards the students will then be placed on work experience with a producer company. • Mowi, has entered into a 3 year arrangement with the Campbeltown Picture House to support the community operations and services provided Employment 3.56. In terms of employment, the Carradale fish farms and the nearby Mowi North Kilbrannan fish farm, consented in 2024, and also serviced from Carradale harbour provide 16 direct jobs. The total number of direct jobs provided by Mowi across Argyll and Bute is 75. The average basic salary of those employed by Mowi in the area is £35,059. The Carradale fish farms have been established since 2009. In that time, they have been successful operations from an economic, environmental, and social viewpoint. No new jobs will be provided by the development proposals however the investment in this new larger pen and net technology will future proof operations and employment levels ensuring that the fish farms continue to be successful as fish farming in Scotland evolves. The sector directly supports 540 jobs in Argyll and Bute, with local fish farms forming an important part of the economies of rural communities. Annual Operational Expenditure 3.57. Annual Operational Expenditure The cumulative operational annual expenditure for the Carradale fish Farms in 2024 was £15M Within this figure, key local expenditures include labour (£739k), repair and maintenance (£131k), other direct costs (£523k) and indirect costs (£235k); a total of £1.63 million in 2024. Expenditure including feed, health and insurance are not sourced locally, although may contribute to the wider national economy. In 2024 Mowi, across all operations, spent over £14.5million directly with local suppliers and service providers based in the Argyll and Bute council area. Proposed Capital Expenditure Arising from the Development Proposals 3.58. The total capital expenditure for the development proposals for the Carradale North and South fish farms, incorporating the new equipment, comprising 12 x 160m pens, 12 x fish nets and 2 x moorings grids and associated components is approximately £3.35 million. Page 48
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LDP2 format template Nov 2023 Carradale Harbour Development Projects 3.59. Following the recent commencement of fish farming operations at North Kilbrannan and recognising the additional investment proposed for the Carradale fish farms, Mowi is Mowi Scotland Limited, Farms Office, Glen Nevis Business Park, Fort William PH33 6RX Registered in Scotland No. 138843 progressing a number of infrastructure improvement projects in Carradale harbour, due to enhanced business needs. These will be delivered in parallel with community benefit elements developed in consultation with the local community with the shared aspiration to re-energise and improve the harbour environs. The developments proposed include the following elements: • A pontoon for Mowi small personnel craft and defined local community boat owners is proposed and has secured planning consent. • A new shorebase for Mowi’s shoreside services and staff facilities is being developed in the former (now remediated) scrap yard with a planning permission recently granted. • A renovation plan is being developed for the locally important and former (fire damaged) Pier House and gardens, to bring the property back into residential use. • A new community harbour building-facility will be provided by Mowi. The type of building, use and location are being informed by a community consultation exercise with the preferred option to be identified in partnership with the community. Economic Value of Aquaculture to Argyll and Bute 3.60. Aquaculture is an important part of the Scottish Marine economy. In 2022, aquaculture generated £337 million aGVA, 0.20% of the Scottish economy and 7% of the marine economy aGVA. Aquaculture employed 2,200 people, 0.08% of Scottish employment and 3% of marine economy employment. Of this, Atlantic (Scottish) salmon production accounted for 96 per cent of all aquaculture value to the economy.1 Scottish salmon is the UK's top food export, with sales worth £844 million in 2024. Exports of Scottish salmon from the Argyll and Clyde regions rose to £125 million last year as demand for Scottish salmon continues to grow. 3.61. Given the above information it has been demonstrated that the proposed development would have a positive economic impact in accordance with NPF4 Policy 25 – Community wealth Building and NPF4 Policy 29 – Rural development which are supportive of rural economic activity. The proposal would also accord with LDP2 Policy 28, the aquaculture specific policy which requires the economic contribution of aquaculture proposals to be assessed. Potential benefits of sustainable site management proposals, which seek to mitigate or reduce environmental risk from fish farming operations, including escapes, disease and sea lice management and manage risk from fish farming operations, including escapes, disease and sea lice management or manage risk through adaptive management in response to environmental monitoring. 3.62. The applicant notes the proposal to use fewer, larger pens than currently utilised at Carradale is intended to benefit containment, sea lice management and fish health by lowering the stocking density, improving water flow, and aiding the response, speed and efficacy of management intervention. A number of documents have been submitted to support the application and detail operational approaches to adaptive management of environmental risks: • Annex 3 Equipment Attestation Page 49
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LDP2 format template Nov 2023 • Annex 4 Containment and Escapes Contingency Plan and Moorings Technical Report • Annex 5 Sea Lice Management, Efficacy and Attestation • Annex 6 Waste Management Plans • Annex 7 Predator Mitigation Plan • Annex 9 Seascape, Landscape and Visual Assessment (Munro Landscape (02.11.2023). • Kilbrannan Sound Environmental Management Plan (February 2024) 3.63. In terms of sea lice management and the control of risk, the applicant notes that effective sea lice management is a critical requirement to protect the health and welfare of farmed fish and to minimise the risk of potential adverse impacts on wild salmonids. The submitted material notes that poor management of sea lice not only generates environmental impacts, but also a significant cost, primarily through compromised fish health and performance. The applicant’s submitted supporting information entitled ‘Annex 5: Sea Lice Management, Efficacy and Attestation’ sets out its policies and aims for sea lice management, before detailing the operational approach and resources that have been implemented and applied at Carradale North and Carradale South marine fish farms during previous cycles. It is noted that an integrated approach is used to meet regulatory and industry guideline treatment thresholds for sea lice as well as the stricter operational intervention thresholds that Mowi aspires to meet. The document also provides an overview of other relevant fish health management procedures. 3.64. In addition, an Environmental Management Plan (EMP) is in place for Kilbrannan Sound. This commits to monitoring and reporting of lice burdens on farmed and wild fish, a framework for cooperation and transparency and a framework for adaptive management with feedback management measures to be taken in response to evidence of negative impacts on wild salmonids. As of 1 November 2025, SEPA has taken regulatory control of sea lice interactions, with the proposed introduction of a national monitoring framework. A planning condition has been attached to require an update of the EMP should the monitoring framework mechanisms be revised. 3.65. SEPA and SGMD have no objections to the proposals and a CAR permit is in place as part of SEPA’s regulatory framework to manage environmental controls for marine fish farms (SEPA reference: CAR/L/1131788). 3.66. It is considered that the proposal would comply with this element of LDP2 Policy 28 and NPF Policy 32. The applicant has submitted supporting documents detail how the development will be operated to minimise environmental risks and use mitigation and monitoring where appropriate. Proposed operational measures which can mitigate or minimise the level of risk of potential impacts (including on other aquatic or coastal interests). 3.67. NPF4 Policy 1 aims to encourage, promote and facilitate development that addresses the global climate and nature crises while NPF 4 Policy 2 is supportive of developments which have been sited and designed to adapt to current and future risks from climate change. It is noted that marine aquaculture is seen as possible solution to global food shortages that are predicted to increase as a result of climate change. Wild Atlantic salmon is not a sustainable food source. 3.68. However, the industry has also been vulnerable to the effects of temperature rises caused by climate change as evidenced by increased levels of mortalities. Marine fish farms in off-shore locations are also more vulnerable to the effects of storm events which Page 50
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LDP2 format template Nov 2023 are increasing as a result of climate change. However, the Scottish Government Marine Directorate are satisfied with the details of the equipment provided by the applicant. Equipment attestations and specifications have also been provided by the manufacturer which state that the equipment has been designed in accordance with the Norwegian standard to withstand the environmental conditions at the development location. 3.69. A number of documents have been submitted by the applicant in relation to the operation of the site (see above). These include: Escapes Contingency Plan, Farm Management Statement, Predator Mitigation Plan; and Farm Waste Management Plan. The applicant has also provided a self-attestation to confirm that the proposed equipment to be used is suitable for this site and an amended Moorings Technical Analysis Report which details the inputs and results from a full technical dynamic analysis for the revised pen and mooring system design, confirming compliance with applicable equipment design requirements. Adherence to these matters will be secured through the use of planning conditions. 3.70. Subject to these conditions being complied with the proposal will accord with NPF 4 Policy 32 – Aquaculture and LDP2 Policy 28 – Supporting Sustainable Aquatic and Coastal Development. Page 51
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LDP2 format template Nov 2023 APPENDIX B – LIST OF CONTRIBUTORS OBJECTIONS 1. James Anderson, Office, 110 Sound Of Kintyre, Campbeltown, PA28 6GA A further 11 proforma objection letters have been submitted by the following signatories: 2. James Anderson, No address provided 3. Vytoldas Medeikis, No address provided 4. John C Galbraith, No address provided 5. David Anderson, No address provided 6. James Coats, No address provided 7. L Ferguson, No address provided 8. Alasdair MacLean, No address provided 9. S Prentice, No address provided 10. Paul McAllister, No address provided 11. A Hamilton, No address provided 12. John Brown, No address provided Page 52
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© Crown Copyright and database right 2025 All rights reserved. OS license (customer) account number AC0000849384 Location Plan relative to; 24/01381/MFF O 0 240 480120 Meters Application Site Page 53
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Ref: ABH1/2009 ARGYLL AND BUTE COUNCIL PROCEDURE NOTE FOR USE AT HYBRID DISCRETIONARY HEARING HELD BY THE PLANNING, PROTECTIVE SERVICES & LICENSING COMMITTEE 1. Hybrid meetings are those that will involve a physical location and facilitate attendees joining virtually if they wish. 2. The Executive Director with responsibility for Legal and Regulatory Support will notify the applicant, all representees, supporters and objectors of the Council’s decision to hold a Hearing and to indicate the date on which the hearing will take place. The hearing will proceed on that day, unless the Council otherwise decides, whether or not some or all of the parties are represented or not. Statutory consultees (including Community Councils) will be invited to attend the meeting to provide an oral presentation on their written submissions to the Committee, if they so wish. Details on how interested parties can access the meeting will be referenced within the same notification. 3. On receipt of the notification the applicant, all representees, including supporters and objectors will be encouraged to appoint one or a small number of spokespersons to present their views to concentrate on the matters of main concern to them and to avoid repetition. Parties who wish to speak at the meeting shall notify Argyll and Bute Council no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting. This is to facilitate remote access (see note 1) and the good conduct of the meeting. 4. The Executive Director with responsibility for Legal and Regulatory Support will give a minimum of 7 days’ notice of the date and time for the proposed Hearing to all parties. 5. The hearing will proceed in the following order and as follows. 6. The Chair will introduce the Members of the Committee, confirm the parties present who have indicated their wish to speak and outline the procedure which will be followed. It is therefore imperative that those parties intending to speak join the meeting at its commencement. 7. The Executive Director with responsibility for Development and Economic Growth’s representative will present their report and recommendations to the Committee. Page 55
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Ref: ABH1/2009 8. The applicant will be given an opportunity to present their case for approval of the proposal and may include in their submission any relevant points made by representees supporting the application or in relation to points contained in the written representations of objectors. 9. The consultees, supporters and objectors in that order (see note 1), will be given the opportunity to state their case to the Committee. 10. All parties to the proceedings will be given a period of time to state their case (see note 3). In exceptional circumstances and on good cause shown the Committee may extend the time for a presentation by any of the parties at their sole discretion. 11. Members of the Committee only will have the opportunity to put questions to the Executive Director with responsibility for Development and Economic Growth’s representative, the applicant, the consultees, the supporters and the objectors. 12. At the conclusion of the question session the Executive Director with responsibility for Development and Economic Growth’s representative, the applicant, any consultees present, the supporters and the objectors (in that order) will each be given an opportunity to comment on any particular information given by any other party after they had made their original submission and sum up their case. 13. If at any stage it appears to the Chair that any of the parties is speaking for an excessive length of time he/she will be entitled to invite them to conclude their presentation forthwith. (see note 3) 14. The Chair will ascertain from the parties present that they have had a reasonable opportunity to state their case. 15. The Committee will then debate the merits of the application and will reach a decision on it. No new information can be introduced after the Committee begins to debate. 16. The Chair or the Governance Officer on his/her behalf will announce the decision. 17. A summary of the proceedings will be recorded by the Committee Services Officer. NOTE (1) If you wish to speak at the hearing you will require to notify the Committee Services Officer no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting. This is to facilitate remote access if required and the good conduct of the meeting. Page 56
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Ref: ABH1/2009 In the event that a party wishes to speak to a visual presentation, this requires to be sent to Committee Services no less than 2 working days (excluding public holidays and weekends) before the commencement of the Hearing; this will not be shared with other parties prior to the meeting but will ensure its availability for the commencement of the Hearing. The Committee Services Officer will control the slides under explicit instruction from the spokesperson(s), it would therefore be helpful if the slides were individually numbered. It would also be helpful if the file size of the presentations is kept to a minimum to mitigate against any potential IT issues – guidance can be provided if required. If it is your intention to join the hearing to observe the proceedings, please advise the Committee Services Officer no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting to facilitate remote access if required. (2) Councillors (other than those on the Committee) who have made written representations and who wish to speak at the hearing will do so under note 1 above according to their representations but will be heard by the Committee individually. (3) Recognising the level of representation the following time periods have been allocated to the parties involved in the Hearing. For the avoidance of doubt the time allocated will be per party and will include for example all supporters/objectors in the half hour slot except where additional time is agreed by the Chair. The representative of the Executive Director with responsibility for Development and Economic Growth – not more than half an hour The Applicant - not more than half an hour. The Consultees - not more than half an hour. The Supporters - not more than half an hour. The Objectors - not more than half an hour. (4) The purpose of the meeting is to ensure that all relevant information is before the Committee and this is best achieved when people with similar views co-operate in making their submissions. (5) Everyone properly qualified as a representee recorded on the application report who wishes to be given an opportunity to speak will be given such opportunity subject to the requirements for notice herein. (6) Should, for any reason, Members of the Committee who are joining remotely lose connection or have any technical issues during the meeting, they will be asked to contact the Governance or Committee Support officer, if possible, by email or instant message. A short adjournment may be taken to try and resolve the connection. If the Members of the Committee are unable to re-join the meeting and a quorum still exists then the meeting will continue to proceed. If a Page 57
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Ref: ABH1/2009 quorum does not exist the meeting will require to be adjourned. For the avoidance of doubt Members of the Committee have to be present for the whole hearing in order to take part in the decision. (7) Should, for any reason, participants joining the hearing remotely lose connection or have any technical issues during the meeting, a short adjournment may be taken to try and resolve the connection. In the event the connection cannot be restored within a reasonable timeframe consideration will be given to the continuation of the meeting. (8) Members of the Committee joining remotely will use the hands up function to indicate to the Chair when they wish to speak to ask a question or make a comment. This function will be monitored by the Chair and by governance staff in attendance. (9) Where a Councillor who is a member of the PPSL has made or wishes to make a representation (on behalf of any party) during the meeting in relation to the application under consideration, they should make their position clear to the Chair and declare an interest. Having done so, they may, at the appropriate time, make the relevant representation and then must retire fully from the meeting room prior to deliberation of the matter commencing. A Councillor, not a member of the PPSL, may make a representation (on behalf of any party) during the meeting in relation to the application then must retire fully from the meeting room prior to deliberation of the matter commencing. (10) The Council has developed guidance for Councillors on the need to compose a competent motion if they consider that they do not support the recommendation from the Executive Director with responsibility for Development and Economic Growth which is attached hereto. I:data/typing/virtual planning hearings/procedure note Page 58
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Ref: ABH1/2009 COMPETENT MOTIONS • Why is there a need for a competent motion? o Need to avoid challenge by “third party” to local authority decision which may result in award of expenses and/or decision being overturned. o Challenges may arise from: judicial review, planning appeal, ombudsman (maladministration) referral. Expenses may be awarded against unsuccessful parties, or on the basis of one party acting in an unreasonable manner, in appeal/review proceedings. • Member/Officer protocol for agreeing competent motion: o The process that should be followed should Members be minded to go against an officer’s recommendation is set out below. • The key elements involved in formulating a competent motion: o It is preferable to have discussed the component parts of a competent motion with the relevant Member in advance of the Committee (role of professional officers). This does not mean that a Member has prejudged the matter but rather will reflect discussions on whether opinions contrary to that of professional officers have a sound basis as material planning considerations. o A motion should relate to material considerations only. o A motion must address the issue as to whether proposals are considered consistent with Adopted Policy of justified as a departure to the Development Plan. Departure must be determined as being major or minor. o If a motion for approval is on the basis of being consistent with policy reasoned justification for considering why it is consistent with policy contrary to the Head of Development and Economic Growth’s recommendation must be clearly stated and minuted. o If a motion for approval is on the basis of a departure from policy, reasoned justification for that departure must be clearly stated and minuted. Consideration should be given to holding a PAN 41 Hearing (determined by policy grounds for objection, how up to date development plan policies are, volume and strength of representation/contention) o A motion should also address planning conditions and the need for a Section 75 Agreement. o Advice from the Scottish Government as contained within Planning Circular 3/2013: Development management procedures on the definition of a material planning consideration is attached herewith However, interested parties should always seek their own advice on matters relating to legal or Page 59
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Ref: ABH1/2009 planning considerations as the Council cannot be held liable for any error or omission in the said guidance. Page 60
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Ref: ABH1/2009 DEFINING A MATERIAL CONSIDERATION 1. Legislation requires decisions on planning applications to be made in accordance with the development plan (and, in the case of national developments, any statement in the National Planning Framework made under section 3A (5) of the 1997 Act) unless material considerations indicate otherwise. The House of Lord’s judgement on City of Edinburgh Council v the Secretary of State for Scotland (1998) provided the following interpretation. If a proposal accords with the development plan and there are no material considerations indicating that it should be refused, permission should be granted. If the proposal does not accord with the development plan, it should be refused unless there are material considerations indicating that it should be granted. 2. The House of Lord’s judgement also set out the following approach to deciding an application: - Identify any provisions of the development plan which are relevant to the decision, - Interpret them carefully, looking at the aims and objectives of the plan as well as detailed wording of policies, - Consider whether or not the proposal accords with the development plan. - Identify and consider relevant material considerations for and against the proposal, and - Assess whether these considerations warrant a departure from the development plan. 3. There are two main tests in deciding whether a consideration is material and relevant: - It should serve or be related to the purpose of planning. It should therefore relate to the development and use of land, and - It should fairly and reasonably relate to the particular application. 4. It is for the decision maker to decide if a consideration is material and to assess both the weight to be attached to each material consideration and whether individually or together they are sufficient to outweigh the development plan. Where development plan policies are not directly relevant to the development proposal, material considerations will be of particular importance. 5. The range of considerations which might be considered material in planning terms is very wide and can only be determined in the context of each case. Examples of possible material considerations include: - Scottish Government policy, and UK Government policy on reserved matters - The National Planning Framework - Scottish planning policy, advice and circulars - European policy - A proposed strategic development plan, a proposed local development plan, or proposed supplementary guidance Page 61
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Ref: ABH1/2009 - Guidance adopted by a Strategic Development Plan Authority or a planning authority that is not supplementary guidance adopted under section 22(1) of the 1997 Act - A National Park Plan - The National Waste Management Plan - Community plans - The Environmental impact of the proposal - The design of the proposed development and its relationship to its surroundings - Access, provision of infrastructure and planning history of the site - Views of statutory and other consultees - Legitimate public concern or support expressed on relevant planning matters 6. The planning system operates in the long term public interest. It does not exist to protect the interests of one person or business against the activities of another. In distinguishing between public and private interest, the basic question is whether the proposal would unacceptably affect the amenity and existing use of land and buildings which ought to be protected in the public interest, not whether owners or occupiers of neighbouring or other existing properties would experience financial or other loss from a particular development. Page 62
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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 North 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. 1 1. INTRODUCTION This application is to be presented to the Planning, Protective Services and Licensing (PPSL) Committee on 17th December 2025. Following the publication of the Report of Handling, the Clyde Fishermen’s Association (CFA) has submitted two further representations to the Council, each reiterating their position of objecting to the proposal as follows: Email from CFA of 10.12.2025: • [Condition 18] Mentions creel vessels, CFA represents both methods of fishing, but its primarily mobile boats who will be impacted by the encroachment into tows. • We've already had productive liaison with MOWI, but [the proposal] will have a significant impact to local fishing boats if approved as proposed in that location. Proposing more liaison after approval will not make it a better fit for fishermen who oppose its new location. As noted they feel a compromise is already the current site. • There is significant feeling from local fishermen of frustration that other regions seem to be changing approach to balance fish farming and wild fishing. This is more often now leading to less approvals on new aquaculture developments, this doesn't seem to be happening in Argyll and Bute in the same way. • We are trying to support sustainable development in wild fishing in Argyll and Bute, but decisions between wild fishing and aquaculture seldom if ever seem to fall on the side of wild fishing, and this is harming the case of co-existence. • 16 safety claims around the country are now being contested as boats are caught in aquaculture kit regularly, most often outwith the limits of the site. • Local fishermen are not happy with the current situation. Page 63 Agenda Item 4
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Further email from CFA of 15.12.2025: • Proposal does not represent a minor relocation to fishermen at all, and we are concerned you would think that is the case for our members. These are local fishermen who already have government license to fish, and have been fishing here for many years. This past week alone three boats have been in the area continually, each with an average crew of around 4 people employed, and more boats will be significantly impacted than those fishing there this week alone. • Fishing is not about how much marine area you can access, it is about the safe and productive grounds, and they are not just anywhere in the sea. You can have vast areas of sea and seafood is only caught in a small area. The area of the proposed relocation of the farm is without question encroaching on provable productive and safe fishing grounds, and so it is in no way a minor relocation for our members, it's a significant loss. • If a farmer works 40 acres and 2 are arable and productive, and a shop receives planning permission to be built on the 2 arable acres which are worked, the farmer will still lose most of his living. It doesn't matter if he has another 38 acres which can't be worked. Discussing the fence parameters of the shop building with the farmer after the build will not benefit the farmer much as his productive land is already lost. This is a similar principle for fishing, except we have the added risk of danger in losing safe and sheltered waters. Sorry to have to scenario plan with on land examples, but this understanding doesn't seem to be widely comprehended by many parties in the marine development space. • We have absolutely provided detail of example fishing tows which this proposed development to both MOWI and the Council, and so all parties are aware that wild fishing is happening and important to local fishing businesses. Indeed fishermen have relayed this directly to MOWI in meetings, and their individual objections to the site directly to the Council, of which I believe at least 11 were received. Local boats are happy to meet with planning officers or Councillors to explain their loss of income and provide accounts. • Often aquaculture developments have site visits for Councillors when proposals are put forward and we are happy to present the wild fishing side via a boat visit, indeed we hope that would bring more understanding and balance. • Landing details and the turnover of the businesses who rely on the catch nationally have been provided, and links to landing stats which are available through the Seafish site and the Scottish Government directly online. There are no figures for the haulage of seafood specifically in Argyll and Bute but it will also be significant as catch is transported from Argyll and Bute to the Central Belt, Northern Ireland and the EU. • The approach we have taken is similar to that taken by Western Isles Fishermen's Association in the Outer Hebrides. WIFA are my colleagues and we work together as sister Associations, however their perspective clearly held more weight with their local council representatives, perhaps because the value of fishing is more closely understood in the Outer Hebrides by its government representatives working with the fishing community. • I think we genuinely have to work more closely so we can help Argyll and Bute Council Planning to understand the value chain of wild fishing in more detail. We want to help where we can, and our members can't afford for there to be any misunderstandings or under estimations regarding the worth of local wild fishing. The Western Isles proposal was a new development, but that makes little difference as the principle is still the same. Important ground will be taken away from wild fishing, and as already explained productive fishing ground is not about sqm meters. Perhaps in a way its more jarring as there is already a suitable MOWI site operating in the area, which fishing try to work with. This feels like pushing a workable compromise into an uncomfortable place for fishermen. We have recently worked with another Salmon Company on a full new site Page 64
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location, and our members had no objections It’s not always the size of the footprint, it’s were its located, and this is a move is straight into valuable traditional fishing grounds. • The evidence is without refute that important fishing areas will be lost, and so it follows that the income of existing local fishing businesses will be reduced, and the wider businesses who rely on them will reduce too. Fishing is a sum of parts making a whole, if you take sections of the business away it can and has resulted in a loss of sustainable family and community businesses/boats, and in this case where aquaculture and fishing are already neighbours and working well this doesn’t seem sensible to us for the area. Better to have a balanced and mixed economy. • We provided the turnover of businesses like Whitby, SFO, West Coast PO, Angelbond and Youngs, all of which our members produce goes too. It's clear these are significant businesses with substantial turnovers, and our member boats help to create those figures from local areas such as this site. We believe this recommendation to support this proposal is a choice to reduce one sectors income and potential to support the growth of another's, and that must be acknowledged. We can't accept we haven’t provided adequate information to prove a negative impact to local fishing, we have. At the moment both sectors are co-existing in the area and this will cause significant avoidable tensions. • MOWI commissioned consultants in Poseidon to look at fisheries and their proposal. Firstly we had very little time to respond to that report, only days for a 50 page report we hadn’t previously seen, so from the start the procedure was very rushed for us. However we did take the time, and we clearly pointed out a number of significant issues with the report including the fact that under 12m boats aren't even captured, and neither the socio-economics of wild fishing in processing, haulage or exports, as it is captured for MOWI. This is not a like for like socio-economic comparison. Only fisheries landings have been compared with a full value chain for MOWI. It is often noted that for every 1 job on a fishing boat around 5 to 8 jobs are related on land (depending on the boat and the economist). No fishermen in our association were approached in the creation of the Poseidon report, and we would recommend looking at value chains of fishing from netmaking, catching, boat yards/engineers, fuel merchants, haulage, exporting, processing, policy development, science and retail to get a picture of the wild fishing chain our members are part of: Fishing data and insight | Seafish • We would certainly be interested in how MOWI justified their projected figures and how they were asked to confirm these projections were accurate? How many new jobs did they say this proposal would create, or would it be existing employees? How many employees will be local to the area or brought in? What new revenue will it bring to the area and how is that proven? • Also can we ask what creelers noted this proposal would be a benefit? As both our creel and mobile members have expressed they are not supportive of this proposal. It would be interesting to see if this is in fact a full time commercial creel fisherman from the area who has said this is beneficial. • We have concerns as at a previous Council meeting for another aquaculture site we were informed in the public meeting that Carradale Fishermen’s Association supported the development, but there is no such organisation. In addition all of the boats relevant to that previous proposal were in the Clyde Fishermen’s Association and against it. We are worried that perhaps a recreational fishermen, or maybe just a member of the public, has been approached and represented as “local creelers”. Particularly given the claims made previously. • Was any explanation provided for change to the site in light of the significant market reduction in Salmon at the moment? https://share.google/h1iN7d94YvOZ3Noc0 • The potential for wild fishing to grow and develop in Argyll and Bute is significant and we want to be an asset to Argyll and Bute and work with you and partners, as the Page 65
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Vision Document we provided shows. We have and will compromise with other sectors where possible, but for our fishermen this is an unfair ask for their sustainability. • At the moment around the coast there are 16 instances of unresolved disputes between fishing boats and aquaculture sites which we are aware of. For example fishing boats claiming they have been caught in unmarked fish farm kit outside the designated locations, and in some instances disputes over thousands of pounds damage to boats and potential risks to life has been created. It’s clear that tensions are rising in some regions, and we would be inclined to suggest where a current compromise is working to an extent for both parties, that would be the best option to continue with rather than moving aquaculture into known wild fishing areas. We aren’t campaigning against the current site and we would rather have a good working relationship if possible with mutual respect for both sectors. • In the National Marine Plan (. 6. Sea Fisheries - Scotland's National Marine Plan - gov.scot ) it notes that: “Existing fishing opportunities and activities are safeguarded wherever possible”. It goes on consideration must be given to: “The cultural and economic importance of fishing, in particular to vulnerable coastal communities”. It also notes that where it is not possible to safeguard wild fishing then a Fisheries Management and Mitigation Strategy should be prepared, and that: “Where it does not prove possible to agree the Strategy with all interests, the reasons for any divergence of views between the parties should be fully explained in the Strategy and dissenting views should be given a platform within the Strategy to make their case” • Firstly we do not believe that existing wild fishing opportunities and activities have been safeguarded wherever possible in this case, it's entirely possible to keep the status quo and have aquaculture and fishing in the area as is. Instead we are probably moving from a space of co-existence between local wild fishing and aquaculture to competitive issues for space, which is not an ideal scenario for those working at sea. • We have made it clear that we do not agree with the proposal and have highlighted a range of justifiable issues with the Poseidon [Commercial Fisheries Impact assessment] report, some of which the consultants raised themselves re data gaps. Aside from the short time in which we had to read it. However we have not been meaningfully involved in a Strategy or had the opportunity to directly put our own views forward in a platform in any Strategy to make our case, as far as we are aware this seems to be a missing step? I would not say that Clause [Condition] 18 addresses those points outlined. • Can we be advised on what steps we can now take to continue to object formally? The purpose of this Supplementary Report is to update elected members on details of further representations submitted Clyde Fishermen’s Association, to identify where relevant matters have been adequately dealt with in the Report of Handling and Committee Report, to clarify where there are new matters and to detail any appropriate response to these matters on the part of the applicant. Officer comment: these matters have already been suitably addressed in the Report of Handling and the Committee Report and do not change the officer recommendation. Where relevant, the applicant provides further detail on technical matters below. 2. APPLICANT RESPONSE TO CLYDE FISHERMENS’ ASSOCIATION This application is for a site modification with a change in area and thus should not be compared with or considered in the same light as a new site proposal. Purpose, Employment & Investment Page 66
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Fundamentally, the purpose of upgrading Carradale sites to fewer 160m pens is to support fish health through optimised operational efficiency. The investment in fewer, larger pens at our Carradale sites aligns with Mowi's strategy to effectively utilise modern pen technologies, maximising the efficiency and effectiveness of fish health management and site operation. This pen upgrade forms part of a wider Carradale enhancement project, which Mowi have been investing in significantly, including development of the North Kilbrannan farm, local community investment, a new shorebase, house restoration, and harbour upgrades, including a shared use pontoon. Mowi has developed a plan for the transition of suitable sites to fewer, larger pens, and Carradale North and South fit the profile for such a site. The use of 160m pens has been very common in Norway over the past 10 years but has only recently been fully embraced in Scotland, delayed mainly by a lack of service infrastructure to deploy, manage and harvest from this size of pen. In recent years though significant investment has been made by Mowi in service vessels, workboats and well boats of a suitable mass that can now handle larger sized pens and associated equipment. In addition, there are operational and resourcing benefits, including fewer nets for inspection and reduced maintenance such as net cleaning, improving localised water quality and associated gill health. In terms of the specific pen centres that are presented, this is a combination of minimising the planning boundary change requested vs existing layouts, whilst bearing in mind the water column depths required for safe instalment of the larger pen grid to support the larger pens. On the inshore side of the pen groups, the bathymetry shallows quite rapidly, and we must maintain a minimum depth on that side, so we cannot move the pens any further shoreward. Instead, to minimise the farm footprint we have endeavoured to reduce the eastwards side moorings as far as practicable. This creates the specific layout presented today. A socio-economic statement was submitted to Argyll & Bute Council as supplementary material in September 2025. Engagement The importance of engaging with commercial fisheries was brought to our attention by the planning committee during our historical North Kilbrannan application, and we have consciously worked to improve engagement as a consequence of this. Our register of engagement captures 17 key interactions up to July 2025 with the CFA. As shown in this register, and via our iterative application process, Mowi have attempted to work with CFA to develop a design for the 160m pens that is both effective and safe from an operational and moorings' perspective, and sympathetic to existing fishing practices. This has involved communication both with CFA representatives, and directly with individual members. Amendments Most significantly, consultation has led to two re-submissions, and a significant reduction of the site moorings by Mowi (submitted Oct 2024, and Sept 2025). Engagement with our moorings designers has allowed us to reduce the proposed site on the eastward side to a minimum, whilst retaining an effective and safe mooring solution. This is at the economic expense of Mowi, as it is made possible by using more heavy duty, expensive solutions. The specific pen centres proposed are designed based on the minimum possible change to existing pen locations, and considering the requirements for certain depths for the pens themselves, as well as effective and reliable moorings. To reiterate, this is now a distance of just 79m for the Carradale North pen group, and 99m for the Carradale South pen group. Following presentation of this compromise, CFA indicated that they would sustain their objection. Page 67
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National Marine Plan: Fisheries Management and Mitigation Strategy (FMMS) FMMS are typically utilised for much larger developments where there is potential for large scale interactions with commercial fisheries, e.g. major offshore wind developments. It is not standard practice for Mowi (or any aquaculture development) to require such a strategy, although they could be adapted to be more appropriate to this scale of development, if deemed necessary. CFA should be reassured that they have not been denied the opportunity to feed into such a document. Mowi does have experience of developing such a document at one fish farm (a new site development), and this was developed after the development was determined. Mowi would be content for this to be included as an item within Condition 18, should it be deemed necessary. Creel Fishing In response to CFA's land-based farming example, we do not see that the seabed is directly comparable to arable/land-based farming. Firstly, the area is not privately owned by either party and does not have defined/fenced boundaries within which fish and shellfish do or do not travel. Indeed, Mowi has witnessed anecdotally that the no-take zones created through our mooring installations, can create enhanced productivity for some species, including commercially important langoustine, lobster, crab and white fish species. Indeed, this effect appeared to be recognised in a meeting with CFA members on the 02.02.2024, when a creel fisherman indicated that he currently shoots his creels close to the existing Carradale moorings (inshore side) for best fishing success. Following this discussion, to endeavour to facilitate this fishing practice most safely, Mowi agreed to send a detailed list of moorings coordinates by email to this individual, and also to send an amended list following installation of the proposed 160m pen mooring grid, if approved. There was verbal agreement from both parties in the same meeting that, since the 160m pen application would create a slight increase in the inshore fishing area, this may offer additional creel fishing grounds. This interaction was perceived by Mowi to indicate a positive response to the proposal by the creel fishermen represented in the meeting. The email exchange and identity of individuals is not shared for data protection reasons. Communication & Disputes Although CFA refer to 16 open disputes between fisheries and aquaculture nationally, we can confirm that Mowi are not aware of any unresolved disputes at this time and have a dedicated pathway to facilitate open communication if any issues are to arise, to ensure they are dealt with in a timely and satisfactory manner. Separate to the development and the planning application, Salmon Scotland, its producing members, and representatives from relevant Fisheries Associations (SFA, OFA, WIFA, CFA, CIFA, SFF) have all agreed to create a series of engagement liaisons, starting in 2026, with a focus on recognising the challenges faced by both sectors, and exploring solutions and opportunities. 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 finfish aquaculture across Scotland. Currently, the group’s objectives are to identify and discuss effectively on issues arising from the interaction of the fishing and finfish aquaculture activities, and to 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 safety. Commercial Fisheries Impact Report & Recent fishing tracks The Commercial Fisheries Impact report by Poseidon considers public commercial fisheries data. It explains the sources of information available and utilised, and acknowledges data limitations that exist across the whole of Scotland. Therefore the uncertainties faced around untracked vessels and public data are not specific to the Development under consideration. Page 68
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The Report by Poseidon details that “Mowi have stated that they would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels”, thereby working to mitigate interactions with small vessels.” In addition, Mowi have reviewed available track data for vessels of interest today, for the preceding 30 days, as far as is publicly available. The vessels referred to by CFA as being active in the area in the past week are not visible in this data. Therefore it is assumed that these boats are less than 12m in length and thus not tracked. This presents data uncertainty, as is the case across Scotland and the regulatory framework. Smaller vessels, if creeling, are expected to be able to continue to operate in close proximity to the farm and as mentioned in the ‘Creeling’ section above, we expect they may actively seek out these waters, and we are willing to facilitate this. As shown in the plot below, six vessels were active in the last 30 days, and only one tracked vessel has passed within the proposed moorings boundary, on the 27th Nov (and close by on 26th Nov). This vessel was travelling at an average speed of 7.4kn, which we assume is indicative of transiting and not active fishing. There are other tracks in the centre of the deep channel that are more indicative of fishing (~2.2kn speed). Local contacts in the Carradale area have also been consulted today regarding recent fishing activities and confirmed that no fishing vessels have been noted adjacent to the existing site, however any that are within a reasonable distance of the area (~1km) are creel vessels. Page 69
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Officer comment: these matters have been suitably addressed and do not change the officer recommendation. 3. ASSESSMENT AGAINST THE NATIONAL MARINE PLAN Officers are of the opinion that the applicant has taken all reasonable endeavours to safeguard existing fishing opportunities by responding to the issues raised by the CFA. Specifically, the applicant has undertaken the following steps in response to concerns raised throughout the process: 1. Engaged with CFA at pre-application stage and throughout. 2. Undertaken detailed moorings analysis and reduced the areas of moorings by 14% in response to concerns raised. 3. Submitted amended plans to accommodate reduced moorings areas. 4. Undertaken Commercial Fisheries Impact Report. 5. Agreed to further mitigation measures to facilitate safe access to creeling grounds close to the proposed new pens. 6. Agreed to planning condition 18 which aims to ensure the proposed mitigation is implemented and further dialogue is possible to enable ongoing co-existence between the two sectors. However, in this instance, the CFA does not agree that existing wild fishing opportunities and activities have been safeguarded and would prefer to keep the status quo, with no changes to the existing Carradale Fish Farm. The CFA also does not consider that they have been meaningfully involved in a Strategy or had the opportunity to directly put their views forward in a platform in any Strategy. The applicant would dispute this, given the ongoing engagement, however, The National Marine Plan sets out that: “Where existing fishing opportunities or activity cannot be safeguarded, a Fisheries Management and Mitigation Strategy should be prepared by the proposer of development or use, involving full engagement with local fishing interests (and other interests as appropriate) in the development of the Strategy. All efforts should be made to agree the Strategy with those interests. Those interests should also Page 70
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undertake to engage with the proposer and provide transparent and accurate information and data to help complete the Strategy. The Strategy should be drawn up as part of the discharge of conditions of permissions granted.” The National Marine Plan further sets out that the content of the Strategy should be relevant to the particular circumstances and could include: • An assessment of the potential impact of the development or use on the affected fishery or fisheries, both in socio-economic terms and in terms of environmental sustainability. • A recognition that the disruption to existing fishing opportunities/activity should be minimised as far as possible. • Reasonable measures to mitigate any constraints which the proposed development or use may place on existing or proposed fishing activity. • Reasonable measures to mitigate any potential impacts on sustainability of fish stocks (e.g. impacts on spawning grounds or areas of fish or shellfish abundance) and any socio-economic impacts. Where it does not prove possible to agree the Strategy with all interests, the reasons for any divergence of views between the parties should be fully explained in the Strategy and dissenting views should be given a platform within the Strategy to make their case. The applicant is content to work with the CFA on the production of a Fisheries Management and Mitigation Strategy if necessary and this is to be secured by condition 18 as suggested in the National Marine Plan. As such officers are satisfied that all reasonable measures have been undertaken to ensure co-existence between aquaculture and local fisheries. 4. MINOR REVISIONS TO CONDITION 18: In response to these further representations to the Council, the applicant has agreed if deemed necessary, to produce a Fisheries Management and Mitigation Strategy and this is to be secured by minor revision to planning condition 18 as follows (additions in bold – please note there was an error in the Report of Handling with regards to the timescales for the original Condition 18 so this is corrected from one month to three): 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 fishing grounds for creeling and other vessels as is reasonably practicable in line with the provisions of The National Marine Plan. Officer response: These matters do not raise any new concerns that have not already been dealt with in the Report of Handling and PPSL Committee Reports and addressed where relevant through the use of planning conditions or revised planning conditions. Page 71
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5. CONCLUSION Given there is an existing operational fish farm in this location, it is a minor relocation of 79m to the east proposed as part of a modernisation plan and we have not been able to fully quantify the local financial impact of the potential loss of fishing grounds specifically linked to the changes proposed, officers feel there are insufficient grounds to recommend refusing the application. We note that there has been ongoing dialogue between the applicant and the CFA throughout the planning process and Condition 18 is intended to ensure that the mitigation offered by Mowi to the local fishing boats is implemented and communication continues to facilitate safe co-existence of aquaculture and local fisheries. The revisions to Condition 18 to implement a Fisheries Management and Mitigation Strategy if deemed necessary, adequately address the requirements of the National Marine Plan in instances where existing fishing opportunities or activity cannot be safeguarded. Author of Report: Shelley Gould Date: 16.12.2025 Reviewing Officer: Peter Bain Date: 16.12.2025 Fergus Murray Head of Development and Economic Growth Page 72
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LDP2 format template Nov 2023 Argyll and Bute Council Development & Economic Growth 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 Planning Hierarchy: Local Application 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 North 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 DECISION ROUTE ☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 ☒Committee - Local Government Scotland Act 1973 (A) THE APPLICATION (i) Development Requiring Express Planning Permission • Modification of existing pens 10 x 120m circumference to 6 pens 8 x 160m circumference pens in a 120 m x 120 m mooring grid matrix, held in two linear rows of 4 pens; • Installation of pole mounted top nets; • Minor relocation of the existing and installed 600 tonne feed barge (ii) Other specified operations • Navigational lighting in accordance with the requirements of the NLB. • Biomass of 2,500 tonnes (B) RECOMMENDATION: It is recommended that: Planning permission be approved subject to the conditions and reasons appended to the report. (C) CONSULTATIONS: Marine Directorate of the Scottish Government (dated 7.11.24): The two pen groups at Carradale North and South are registered as one site with Scottish Ministers in the applicant’s aquaculture production business authorisation. Therefore, the Fish Health Page 73
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LDP2 format template Nov 2023 Inspectorate (FHI) have considered these concurrent applications together and provide combined comments for these applications (ref: 24/01381/MFF and 24/01382/MFF). Summary of information required • Confirmation of net depth • Details of the practical time taken to perform physical treatments on the modified site • Details of the permitted quantities of chemotherapeutants on the South pen group and the practical time taken to conduct these treatments Marine Directorate of the Scottish Government (dated 11.12.24): Having reviewed the further information submitted by the applicant on 03/12/2024 the following comments are made: Confirmation of net depth Depth of net sidewalls is confirmed as 12m for inside pens and 15m for outside row of pens. This is satisfactory for an acceptable stocking density level of below 22kg/m3. Details of the practical time taken to perform physical treatments on the modified site - The FLS system can treat 3x 160m pens per day, so could complete treatment of each pen group in 2 days and the whole site in 4 days. Details of the permitted quantities of chemotherapeutants on the South pen group and the practical time taken to conduct these treatments The revision to the permitted quantities of bath chemotherapeutants in the new CAR licence application would allow bath treatments of azamethiphos to be undertaken on the North or South pen group at a rate of 1 pen/day equating to 6 days for each full pen group. It is noted that the pen groups may not discharge azamethiphos at the same time, therefore should treatment of both pen groups be required for the whole site this would take 12 days. Consented levels for the in-feed treatment emamectin benzoate allows one use per cycle on each of the North and South pen groups at maximum biomass or more frequent uses earlier in cycle when biomass is lower, as it has been utilised in this manner in recent production cycles. Sea lice efficacy The CAR licences for both sites permit sufficient quantities of Azamethiphos and Deltamethrin to allow the treatment of each site within 6 days and 3 days respectively with tarpaulin treatments. The applicant has indicated that the Modelled Maximum Quantity of the in-feed treatment Emamectin benzoate (SLICE) is sufficient for a single treatment at maximum biomass (at each site). Given the exposed location of the site, there are concerns over the welfare of young fish being stocked on site and their ability to withstand the currents and environmental conditions experienced on site. It is noted the applicant state that larger smolts will be stocked onto the site; the production plan details that the average size of smolts being stocked will be 164g, with a production cycle of up to 18 months. Details of the considerations made on the suitability of the site for fish of this size whilst ensuring any impacts to welfare are mitigated against should be provided. This information may be included in the Veterinary Health and Welfare Plan which is referenced but not provided. No further information required. Scottish Environmental Protection Agency (dated 29.10.24): We have no objection to the proposed development from a planning perspective. We can confirm that we have already authorised the change under CAR. Page 74
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LDP2 format template Nov 2023 Argyll and District Salmon Fishery Board (dated 24.10.24): Our consultation response to the application is made in respect to the importance of populations of Atlantic salmon present in the rivers of Kintyre and Isle of Arran, and several smaller coastal rivers that also support populations of sea trout which support active recreational fisheries, local employment, and economy. Our primary interest remains the reduction of pressure on wild salmonids from sea lice and escaped farm fish, and we broadly support innovation in the aquaculture sector to develop production methodologies which can mitigate for impacts on wild fish. In principle, Argyll DSFB have no objection to the change in fish pen sizes. However, on the premise that the potential failure in containment in one of the six larger cages proposed may pose some increased risk of interactions with wild fish populations given that a higher number of post-smolt salmon will be held in fewer, but larger pens. We also note and appreciate the measures described in the escapes contingency plan provided with the application which detail measures to reduce the potential for escapes of farm stock to occur. We are, however, mindful that escapes of farm fish remain a possibility as there has been a significant escape of farm fish from this site in recent years. We appreciate the most recent equipment designs may improve containment measures but the risk to wild salmon populations remains. We are, however, mindful that escapes of farm fish remain a possibility and that we need to be assured that the containment measures put in place are sufficient to protect local wild salmon populations over time. To this end we ask that a regular programme of genetic surveillance of local wild salmon populations is undertaken over the lifetime of the farm. This programme of genetic monitoring should be capable of identifying any introgression of escapee farm salmon with wild salmon populations in the area. Argyll DSFB, expect such a programme of surveillance to be embedded within an Environment Monitoring Plan (EMP). In summary, Argyll DSFB has no objection to the proposed change in fish pen size at the Carradale farm site in the understanding that an EMP that monitor the genetic health of wild salmon populations in the Awe Fisheries District is a condition of any change in the planning permission. Argyll Fisheries Trust: No response. NatureScot (dated 15.10.2024): Confirmed no comments. Historic Environment Scotland (dated 30.10.24): Confirm that there are no marine or terrestrial heritage assets within statutory remit within the development site boundary or within its vicinity. No comments. West Highland Anchorages and Moorings Association (WHAM) (15.10.2024): no comment. Northern Lighthouse Board (dated 18.10.24): Consultation response includes details of lighting and marking requirements. Royal Yachting Association (dated 30.10.24): RYA Scotland has no objection to this application. However, it is noted that the outer perimeter of the farm will extend 85 m further east into the busy Kilbrannan Sound. It will be important to ensure that this expansion is widely publicised including through an update to the Clyde volume of the Clyde Cruising Club Sailing Directions and Anchorages book and that care is taken to ensure that the lights are well maintained at all times as a failure could have unfortunate consequences in conditions of poor visibility. Page 75
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LDP2 format template Nov 2023 Marine and Coastal Development Policy Officer (dated 18.11.24): There is no objection to the proposed changes at Carradale North fish farm. In terms of possible containment failure, I do however agree with the Argyll District Salmon Fisheries Board (ADSFB) in that it will be important for the Applicant to monitor the genetic health of local wild salmon populations through a programme of genetic surveillance. This should be stipulated within the Applicant’s Environmental Monitoring Plan (EMP). Planning conditions to be applied to the Carradale North Fish Farm 1. The Applicant is asked to submit their EMP. 2. The Applicant will not use Acoustic Deterrent Devices (ADDs). If ADDs are proposed at the site at any time in the future, the Applicant must apply for a European Protected Species Licence from the Scottish Government Marine Directorate - Licensing Operations Team (MD-LOT); including immediate notification and an ADD usage report with daily logs to be communicated with NatureScot and the Planning Authority on request. 3. Daily recording of wildlife interactions (entrapment/entanglement) with the site and the reporting of data at six-monthly intervals. The six-monthly reports are to be communicated with NatureScot and the Planning Authority. 4. Immediate notification to NatureScot and the Planning Authority of wildlife entrapment/entanglement, as stipulated by NatureScot. 5. To implement a monitoring programme, as stipulated by NatureScot. 6. To implement adaptive management approaches based on monitoring findings (as agreed with NatureScot in consultation with the Planning Authority). Update: Having reviewed the additional supporting documentation submission from Mowi for both planning applications: 24/01381/MFF - Carradale South Fish Farm and 24/01382/MFF - Carradale North Fish Farm, there are no further comments to add. Clyde Fishermen’s Association (dated 1.11.2024 & 5.11.24): On this occasion efforts were made to inform the CFA of the plan for the extension. MOWI also listened to concerns and comments presented by the fishermen who attended a meeting in February 2024. MOWI also advised of their intention to submit plans and slight alterations they would make. So in respect to communication in this particular project it was improved in that dialogue did occur and we appreciated the mutual effort fishermen and MOWI made. However, unfortunately as an association our member feedback has been that they would have to object to the planning applications above in the strongest possible terms. They feel the current arrangement is already an existing example of sharing space and compromise which works to an extent for both parties, and this proposal would detrimentally harm fishing unnecessarily when both sectors can continue to exist under the current arrangements. The fishermen from our membership were clear at the online meeting in February 2024 that a move of the current site closer to the East and further into the deep water would cut into the main tows of the indigenous fishing fleet who rely on this area for their livelihoods. This area is vital to the socio-economics of local fishing communities. The feedback from local fishermen is that this area is essential to fishing and could not be lost without risking the viability of local productive fishing boats and the loss of jobs. It is prime fishing ground for catching fresh wild seafood. Whilst we appreciate MOWI have now presented a model which is reduced on their initially proposed Eastward move, in reality even the reduced Eastward expansion in into the deep fishing water is significantly detrimental to local fishermen, just as the original proposal also was. Neither new options work for local fishermen. Local fishermen are not simply being difficult as they currently work with a situation of compromise right now Page 76
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LDP2 format template Nov 2023 which is more palatable to most fishermen. The current MOWI site initially meant a loss of ground to local fishermen so many already feel a compromise and balance has already been reached. It should be noted that many fishermen do have environmental concerns regarding aquaculture, so a current working situation should not be underestimated in terms of its value for local stability of relations and food production. Local fishermen feel the fairest compromise has already been reached previously, and this would be that the site remains at its current location and does not extend onto another deeper footprint in direct conflict with fishing patterns. A continuation of the current situation would allow both aquaculture and local fishing to continue to co-exist in the area and work alongside in the same vicinity. The extension of the aquaculture site Eastward would be the expansion of one sector at the cost of another local sector. The CFA feel this proposal doesn’t make sense when the current activity sites of aquaculture and wild fishing in the area currently works to some degree for both sectors. We hope Argyll and Bute Council should want to maintain both of the sectors in the area with a degree of harmony or at least good relations, not sacrifice one for the expansion of the other if both can co-exist. We appreciate MOWI may be disappointed if they are not able to expand/move the site, but we must reiterate we feel a compromise has already been reached on balancing wild fishing with aquaculture in this location which saw local fishing curtailed a number of years ago. Concerns raised on the impact on local fishing tows at the proposed site as well as wider impacts on the fishing community at Carradale Harbour and the fishing which takes place here is an important employer of local fishermen, exporters and processors and retailers in both Carradale, Campbeltown and well beyond. Applicant response to CFA (22.5.2025): We understand the concerns expressed on spatial conflict by commercial fishing stakeholders. We also acknowledge the need to interact with other marine users who may be impacted by fish farming, including fishermen with a view to establishing mitigation that allows the shared use of the marine space, avoiding and minimising potential displacement effects. We have focussed on establishing design mitigation to ensure that the proposed mooring areas have the minimum spatial footprint whilst maintaining structural integrity to ensure containment at the farms. Through the design of the development proposals, we have worked to reduce the overall extent of the mooring areas, whilst ensuring that the mooring systems meet all required technical design standards and is capable of withstanding the physical characteristics of the development locations. There is no recognised single data source for establishing a locational baseline of commercial fishing activity, and there remains data uncertainty on frequency and intensity of fishing activity, however the information provided by the CFA on local fishing activity allowed for further modelling analysis and reduction of the moorings systems for each of the development locations. A reduction in the fish farm moorings area, from that presented in the respective planning applications is now proposed for both developments. A more detailed breakdown of the iterative changes in the extent of the respective moorings areas through the process for planning approval is presented below. Moorings Design Mitigation An initial, indicative moorings boundary for the Carradale fish farms was presented in the applications for screening submitted to Argyll and Bute Council, which were subject to Page 77
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LDP2 format template Nov 2023 consultation. Following screening and in response to comments received from the CFA, a consultation meeting was held with the CFA (and local members) on 2 February 2024 to discuss and understand fishing grounds and activity to the east of the fish farms. From the information presented on fishing grounds and use there was a commitment from Mowi to re-examine the extent of the mooring’s areas for each development with the aim to reduce their extent. Further moorings design modelling was undertaken which subsequently confirmed the ability to reduce the indicative moorings boundary by 250m on the deep water, eastwards side. In addition, the moorings boundary to the west of Carradale south was adjusted eastwards by 56m, to facilitate improved access for creel fishermen (as informed by CFA meeting, pers. comms.) on the inshore side of the fish farm. The amended moorings layout-boundaries for both Carradale North and Carradale South fish farms were then presented with the respective planning applications. The total development area (including moorings) for the original proposals subject to screening, was 0.826km2 for Carradale North, and 0.818km2 for Carradale South. Following consultation and the above revised technical moorings analysis, and as submitted for planning approval, the extent of the mooring’s areas were reduced to 0.471km2 for Carradale North, and 0.471km2 for Carradale South. Post planning applications submission and following further consultation advice from the CFA and provision of new data on fishing use of the area to the east of the fish farms, including fishing vessel AIS tracks, further moorings modelling was undertaken. The new fisheries data ensured that the modelling design analysis considered the additional fishing information (AIS tracks). The analysis focussed on the east side of the development locations and further moorings design mitigation that would avoid or reduce potential displacement effects from the respective developments. The new analysis confirmed that with a further 50m reduction to the proposed moorings boundary to the east of both fish farms could be safely accommodated. It was also determined that it was possible to remove the NE corner of the Carradale North moorings boundary, and the SE corner of the Carradale South moorings boundary as further mitigation aimed at maintaining as much access as possible to the fish grounds to the east of the fish farms. Following the refined technical moorings analysis, the extent of the respective moorings’ areas for both development proposals have been further reduced to 0.410 km2, a reduction of 13% compared to moorings area presented in the planning applications. A comparison of the mooring areas for the current operational fish farms vs proposed development is presented below: Moorings area – current 120m pens Moorings area – proposed 160m pens Carradale North 0.330 km2 0.410 km2 Carradale South 0.405 km2 0.410 km2 We would estimate approximately 95% of the supplied AIS (fishing vessel) tracks are now out with the proposed mooring development areas and any potential displacement effect would be minor compared to the present baseline position, with two operational fish farms in place. A site plan showing the revised moorings areas for both development proposal with geo referenced AIS fishing vessel tracks is annexed to this response (Annex 1). This document should be treated as Confidential and be detached from this response as it contains commercially sensitive information on fishing grounds. An amended Moorings Technical Analysis Report is annexed as a separate document to this response (Annex 2). The report details the inputs and results from a full technical dynamic analysis for the revised pen and mooring system design, confirming compliance with applicable equipment design requirements. Page 78
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LDP2 format template Nov 2023 Operational Mitigation In addition to embedded design mitigation to prevent conflict with commercial fishing Mowi can also commit to a series of operational mitigation measures. 1. Following site installation, the installed mooring anchor coordinates will be shared with local fishing vessels/CFA and the relevant fisheries representative bodies to allow bottom trawling to be undertaken as close to the mooring infrastructure as safely possible. 2. If appropriate and subject to other navigational considerations and approvals Mowi is content to provide for enhanced navigational markers for the anchor locations to the east of the fish farms to develop a safe transit-trawling corridor past the sites. 3. Following installation, the majority of the area taken up by the mooring lines for each development proposal will still be accessible for static gear fishing with full exclusion only required during maintenance of mooring lines or boat operations. Mowi would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels within the mooring’s footprint of the development sites. 4. Mowi would be willing to work with the CFA to improve communications and liaison with local commercial fishing vessels on farming operations and activities (such as equipment installation) and to provide a mechanism whereby areas of conflict could be discussed and resolved. If deemed appropriate we would be willing to work with the planning authority to find suitable wording to capture this as a condition on any planning decisions. Conclusion Through a detailed and exhaustive design process for the mooring systems for each development, it has been possible to reduce the length of individual mooring lines to ensure the mooring areas have the minimum footprint. • The extent of the mooring’s areas presented in the planning applications were 0.471km2 for Carradale North, and similarly 0.471km2 for Carradale South. • Following the revised technical moorings analysis, the extent of the respective moorings’ areas have been reduced (from planning application details) to 0.410 km2 (13% reduction) for both proposed development sites (Carradale North and Carradale South fish farms). • While the focus of our attention has been developing embedded site design mitigation to allow continued access to fishing grounds and avoid (or reduce) displacement effects to commercial fishing there are also a number of operational mitigations measures we can implement to promote and facilitate fishing with and in close proximity to the site. In particular we would seek to build on the effective working relationship established through this process with the CFA and extend this to the establishment of better local engagement forums with commercial fishing interests in Kilbranann Sound. We understand the frustration and concerns of commercial fishermen on spatial squeeze of accessible fishing grounds. Aquaculture has shared concerns on the threats of cumulating pressures on use of shared marine spaces, and we have tried to limit our use of the marine environment at Carradale to ensure we avoid (or minimise) the potential for displacement effects, supporting the principle of mutual co-existence with commercial fishermen. Next Steps It is intention to proceed with a formal amendment to the planning applications on to revise the mooring areas in accordance with the above. The requisite amended application forms and associated updated supporting information, including revised plans will be submitted in due course. Data limitations and uncertainties exist with regards to the available evidence on the frequency and scale of fishing activity adjacent to and Page 79
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LDP2 format template Nov 2023 within the development areas and the extent of any potential displacement effects. Accordingly, we are additionally considering the commission an independent desktop review to better characterise commercial fisheries within the proposed development site. The intention is to identify the key fisheries interests for a finer scale analysis and scope potential interactions with the proposed development infrastructure. Officer comment: revised plans have been submitted following the discussions with CFA and the results of the Technical Moorings Report. Update: The applicant has commissioned and submitted a further Commercial Fisheries Impact Assessment by Poseidon (October 2025) to assess the nature and level of fishing activity in the Kilbrannan Sound areas of the western arm of the lower Firth of Clyde; to examine the likely spatial and temporal impacts of the farms’ redevelopment on identified fishing activities; and to provide an independent impact assessment and suggest possible mitigation options. This report has concluded that the proposed site is located within the ICES rectangle 40E4 and around 10,600 t of mainly shellfish are landed from this area, worth some £25.6 million per annum over the c. 2,500 km2 of statistical rectangle 40E4. The proposed site’s combined mooring area is just 0.82 km2 and from analysis undertaken Based on AIS data records over a five year period (2019 – 2024) only nine (1.4%) were within the new proposed planning boundary and four (0.3%) were within the proposed mooring boundary. This suggests that the planning boundary is the effective westward limit of bottom trawling this side of the Kilbrannan Sound. This is around 300 m away from the outermost pens under the current configuration and 225 m from the outermost pens under the proposed configuration. Based on this evidence, the proposed move to the east will not have any significant impact on bottom trawling activities, although there will be very little margin for error in navigation. Although not confirmed, this is also likely to be the case for the smaller scallop dredging fishing in the same area. Although not verified by the AIS data (most creel boats do not have historical AIS track records but keep private plotter records and are now having to adopt i-VMS), crab and lobster creeling is likely to be located in the rocky, shallower water of the western inshore part of the site. Nephrops creeling could take 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 (see the two sections above), this is unlikely. Clyde Fishermen’s Association Response to Posiedon Report (14.11.2025): CFA reiterate that as the local fishing association with over 40 fishing boats in our membership, we represent the majority position of those vessels and their crew. We are extremely concerned the local and national socio-economic value of coastal fisheries and their onward benefits and place in the link of local economies is not well understood or downplayed. Most local fishermen in Argyll and Bute will emphasis a lot of safe and productive ground has been lost to aquaculture in recent years, and often they feel their businesses and perspectives are not being successfully fully heard. We note in the Poseidon report that a small percentage of local fishing area is to be impacted, however in a large marine area it is often the case that an area which is under 5% of the total area could be the most productive and safest, therefore using a mitigation metric in terms of percentage of total area lost really doesn’t make sense. It’s the productivity of that area and its safety which should be considered. Page 80
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LDP2 format template Nov 2023 Local fishermen met with MOWI some time ago and provided fishing tracks of their activity, some of which will be recorded on AIS and some which would not have been. The fishermen explained how important this area is to them in person, and the provided tracks clearly showing creep into important fishing grounds via the proposal. The local fishermen feel the current aquaculture site co-existing with local fishing in the area is already a compromise, but this change would be a step too far for loses for local fishing boats. We note that the Poseidon report acknowledges their report doesn’t capture vessels not using AIS, and this will represent a good number of local boats. The Scottish Government are currently looking at improved ways to monitor vessels to make sure all activity is captured and the monitoring systems we have are more effective. It is without dispute that those local vessels not using AIS won’t have been factored into this assessment at all, and so the assessment will be missing out vital detail for fishing. Had we a similar opportunity and resource to commission a similar style report for wild fishing we are sure it would show a very different picture in socio-economic terms. We also note that the time period landings and activity the Poseidon report covers the period of both Brexit redtape impacting catching and exporting of seafood and the covid period. During both of these events many fishing boats were forced to tie up or operate in a much reduced capacity due to domestic and international market shut down/reduction. Indeed for periods during this timescale fishermen needed government support via grants to survive as did many businesses. Whilst fishing was returning to some normality nearer the end of this period, it wouldn’t be fair to assess the socio- economics of this period on a typical metric for the fishing sector. The Poseidon doesn’t touch on the value of the landings into Northern Irish ports (around £45m total landings, some of which will be caught in the Clyde Marine Area). Cumulative issues are not considered in this report either. In the Marine Area of the Clyde we have 5 Marine Protected Areas, a weekend ban on mobile fishing, a seasonal closed cod box, Royal Navy closed areas, numerous aquaculture sites, No Take Zones and a number of energy cables particularly around Carradale, with more planned in the near future. In addition we are going to consultation shortly for Priority Marine Feature Closures and more Marine Projected Areas and rewilding projects. If we want to have a vibrant sustainable fishing fleet, the boats need space to fish, and locally this would unfortunately be another restriction they can ill afford. Death by a thousand small cuts for fishing shouldn’t be an option we choose if resilience and development is an option. We have good stock advice for the area and latent capacity in fishing which is also a socio-economic opportunity and potential for the area which shouldn’t be discounted. This year ICES advised a 54% increase in nephrops alone for the West Coast (21,654 tonnes), there is scope to develop fisheries not just in nephrops but beyond the currently fished stocks. Local Fishermen have set out a vision for development for fisheries in the area which can be found on the link below in short and long version: Science & Policy - Clyde Fishermen’s Trust We have also invested heavily in training courses and a training centre to service the whole Clyde area for fishing, and we are doing our best to boost the socio-economics of our local fishing sector by innovation and development, but we can only successfully achieve this well if fishing is resilient and reflexive, we cannot always be the losing party in respect to marine access, it will defeat the work fishermen from the Argyll and Bute region and the Clyde region beyond are investing into a better future. Page 81
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LDP2 format template Nov 2023 We also note the Poseidon report does not capture the onward value of fishing beyond. Fishing supports the crew on the boats and their families, but it also supports haulage, retail and hospitality domestically and internationally, processing and exporting, boatyards and engineers, fuel merchants, policy work, supermarkets and accreditation companies Officer comment: please see assessment of commercial fisheries impacts in Section 3 of the attached Appendix A - Committee Report. Argyll and Bute Biodiversity Officer (dated 08.11.24): No comments to make. Argyll and Bute Environmental Health (dated 4.9.24): No comments but notes that construction work can be very noisy and there may be a need to protect the amenity for nearby sensitive receptors in the locality of the development. Officer comment: The applicant has committed to mitigation measures to protect neighbouring amenity from operational noise and light and adherence to this will be secured by planning condition. (D) HISTORY: 09/00905/MFF Formation of new 14 cage fish farm including foodstore/service pontoon. (Approved 11.11.2009) 14/01047/MFF Alterations to existing marine fish farm by enlargement of mooring grid to increase cage spacing, without extension of mooring area or changes in number or size of cages (Approved 18.7.2014) 15/00127/MFF Formation of fish farm (Atlantic Salmon) comprising the siting of fourteen 100 metre circumference cages served by feed barge associated with adjacent site. (Approved 4.11.2015) 15/01939/MFF Re-equipment of marine fish farm from 14 no. 100 metre circumference cages to 10 no. 120 metre circumference cages and retention of feed barge (Approved 14.9.2015) 15/03017/MFF Formation of fish farm (Atlantic Salmon) comprising the siting of ten 120 metre circumference cages served by feed barge associated with adjacent site. (Approved 23.12.2015) 18/01172/SCRSCO Screening and scoping request for alterations to and extension of existing fin fish farm and increase in biomass from 2500 tonnes to 3750 tonnes (Opinion Issued 19.7.2018) 19/00107/PNMFF (north) Installation of replacement pens and net (PA Not Required 26.7.2019) 23/00142/SCREEN Screening Opinion for reconfiguration of infrastructure from 10 x 120m circumference cages to 6 x 160m circumference cages with a parallel minor relocation into deeper water (Negative Screening Opinion issued 6.4.2024) (E) PUBLICITY: Page 82
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LDP2 format template Nov 2023 ADVERT TYPE: Regulation 20 Advert Local Application EXPIRY DATE: 15.11.2024 (F) REPRESENTATIONS: (i) Representations received from: James Anderson, Office, 110 Sound Of Kintyre, Campbeltown, PA28 6GA A further 11 proforma objection letters have been submitted (please see Appendix B for a list of the contributors). Representations are published in full on the planning application file and are available to view via the Public Access section of the Council’s website. (ii) Summary of issues raised: • Impact on local fishermen and families • Better areas available for expansion • Concern about ability to influence planning decisions Officer response: the impact on commercial fisheries is considered in detail in Section 3 of the attached Committee Report – Appendix A. In summary, officers consider that the applicant has engaged proactively with the Clyde Fishermen’s Association from the inception of the proposed project and in response to concerns raised has commissioned detailed technical analysis to reduce the extent of the moorings area by 14%, with the intention of minimising the impact on the local fishing industry. The applicant has also proposed further operational mitigation measures and ongoing engagement in response to the CFA’s sustained objection. A planning condition has been applied to support the establishment of a local engagement/liaison forum and agree mechanisms for operational mitigation to support the principle of co-existence with the local commercial fishing activity in the Kilbrannan Sound. It is further noted that Argyll District Salmon Farming Board support the proposed change in fish cage size and configuration on the basis that the changes will include the use of the most robust modern cage technology and fish farm handling procedures. (G) SUPPORTING INFORMATION Has the application been the subject of: (i) Environmental Impact Assessment Report: ☐Yes ☒No (ii) An Appropriate Assessment under the Conservation (Natural Habitats) Regulations 1994: ☐Yes ☒No (iii) A Design or Design/Access statement: ☐Yes ☒No (iv) A Sustainability Checklist ☐Yes ☒No Page 83
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LDP2 format template Nov 2023 (with reference to the requirements of LDP2 Policy 04) (v) A report on the impact of the proposed development eg. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: ☒Yes ☐No Planning Application: Overview (Supporting Document) including: Annex 1 Site Plans and Charts Annex 2 Equipment Plans and Elevations Annex 3 Equipment Attestation Annex 4 Containment and Escapes Contingency Plan and Moorings Technical Report Annex 5 Sea Lice Management, Efficacy and Attestation Annex 6 Waste Management Plans Annex 7 Predator Mitigation Plan Annex 8 Screening Opinion – EIA Not Required Annex 9 Seascape, Landscape and Visual Assessment (Munro Landscape (02.11.2023). Kilbrannan Sound Environmental Management Plan (February 2024) Post submission: Mowi Statement of Mitigation (12.9.2025) Mowi Socio-economic Supporting Statement (12.9.2025) Moorings Technical Analysis Report, Reference GFME-TR- 076, dated 18 February 2025 Commercial Fisheries impact assessment from a revised pen layout at the Carradale fish farm – Phase 1 Report – Desktop Evaluation (October 2025) (H) PLANNING OBLIGATIONS Is a Section 75 agreement required: ☐Yes ☒No (I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or 32: ☐Yes ☒No (J) Section 25 of the Act; Development Plan and any other material considerations over and above those listed above which have been taken into account in the assessment of the application (i) List of all Development Plan Policy considerations taken into account in assessment of the application. National Planning Framework 4 (Adopted 13th February 2023) Part 2 – National Planning Policy Page 84
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LDP2 format template Nov 2023 Sustainable Places NPF4 Policy 1 – Tackling the Climate and Nature Crises NPF4 Policy 2 – Climate Mitigation and Adaption NPF4 Policy 3 – Biodiversity NPF4 Policy 4 – Natural Places NPF4 Policy 12 – Zero Waste Productive Places NPF4 Policy 25 – Community Wealth Building NPF4 Policy 29 – Rural Development NPF4 Policy 32 – Aquaculture Argyll and Bute Local Development Plan 2 (Adopted February 2024) Spatial and Settlement Strategy Policy 04 – Sustainable Development High Quality Places Policy 08 – Sustainable Siting Policy 14 – Bad Neighbour Development Diverse and Sustainable Economy Policy 28 – Supporting Sustainable Aquatic and Coastal Development Sustainable Communities Policy 59 – Water Quality and the Environment Policy 63 – Waste Related Development and Waste Management High Quality Environment Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 74 – Development Impact of Sites International and National Importance (ii) List of all other material planning considerations taken into account in the assessment of the application, having due regard to Annex A of Circular 3/2013. • Third Party Representations • Consultation Reponses • Planning History • ABC Technical Note – Biodiversity (Feb 2017) • ABC Landscape Studies • Scotland’s National Marine Plan (2015) (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: ☒Yes ☐No The proposal is Schedule 2 development and a Negative Screening Opinion (ref: 23/00142/SCREEN) was issued by the Council on 3.3.2023. (L) Has the application been the subject of statutory pre-application consultation (PAC): ☐Yes ☒No Page 85
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LDP2 format template Nov 2023 (M) Does the Council have an interest in the site: ☐Yes ☒No (N) Requirement for a pre-determination hearing: ☐Yes ☒No In deciding whether to exercise the Council’s discretion to allow respondents to appear at a discretionary hearing, the following are of significance: • How up to date the Development Plan is, the relevance of the policies to the proposed development and whether the representations are on development plan policy grounds which have recently been considered through the development plan process. • The degree of local interest and controversy on material considerations together with the relative size of community affected set against the relative number of representations, and their provenance. The current Local Development Plan was approved in 2024. NPF4 which was approved in 2023 contains a similar criteria-based approach in relation to aquaculture applications. It is considered that the development plan is up to date. At the time of writing this application has attracted 11 objections from local fishing boat operators relating to conflict over fishing grounds. No objections have been raised by statutory consultees in relation to these matters. Furthermore, it is noted that the site is already in operation for marine fish farming and there will be no overall increase in biomass as a result of the proposed changes to pen sizes. Officers consider that the relocation of Carradale North and South represents a small percentage of the available fishing grounds and it is noted that through further discussions, revised moorings have further reduced the impact on local fishing activity. It is further noted that the modernisation of marine fish farming activity at this site is welcomed by statutory consultees for benefits to fish health and the applicant has committed to ongoing communication with local fishing boats to maintain access to dishing grounds wherever possible. It is not considered that there would be merit in holding a Pre-determination Hearing as all planning matters raised as objections have been suitably addressed through the submitted material and/or through the use of planning conditions. It is the view of officers that a pre- determination meeting therefore would not add value to the decision-making process in this instance. (O)(i) Key Constraints/Designations Affected by the Development: (ii) Soils - Not applicable as this is a marine development (iii) Woodland - Not applicable as this is a marine development (iv) Land Status / LDP Settlement Strategy - Not applicable as this is a marine development Page 86
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LDP2 format template Nov 2023 (P) Summary assessment and summary of determining issues and material considerations This application is for a change of equipment and a minor relocation of an existing marine fish farm in the Kilbrannan Sound approximately 400m off the eastern shore of the Kintyre Penninsula. The proposal would replace the existing 10no 120m circumference pens with 6 x 160m pens in a formation of 3 x 2 along with the slight change in the position of an existing 650 tonne feed barge which would be located to the south of the group on the shore side. The site would continue to be serviced from the company’s existing shore base located at Carradale Harbour. The proposed development is located approximately 1.8 km north of Carradale village on the western edge of Kilbrannan Sound and east of the Kintyre peninsula. The smaller hamlet of Grogport lies approximately 2.6 km north west of the Site. There is to be no change to the consented biomass for the site. The proposal is part of a wider 5 year project by the applicant to upgrade and modernise fish farming pens to bring about a number of benefits: • Improved health and safety conditions through the upgrading of equipment; • Improved health and welfare of fish. • As the biomass is not increasing the density of the fish will be reduced and fish can be treated more efficiently in fewer pens, reducing amenity impacts. This proposal is not EIA Development. The recommendation on this application has been guided by the consultation responses from Scottish Government Marine Directorate, NatureScot, SEPA, Argyll District Salmon Fishery Board, Historic Environment Scotland, Northern Lighthouse Board, Royal Yachting Association, Argyll and Bute Environmental Health, and the Argyll and Bute Marine and Coastal Officer. Representations received have been addressed in Section F of this report (above) and against the planning policies of the adopted Development Plan which comprises NPF4 and LDP2 as well as other material considerations, including those relating to marine planning (see Appendix A). The proposal would accord with Development Plan policy and accordingly, it is recommended that planning permission be approved subject to conditions (Q) Is the proposal consistent with the Development Plan: ☒Yes ☐No (R) Reasons why Planning Permission or Planning Permission in Principle Should be Granted: The proposal is considered to be consistent with the relevant provisions of the Development Plan, and there are no other material considerations of sufficient significance to indicate that it would be appropriate to withhold planning permission having regard to s25 of the Act. (S) Reasoned justification for a departure to the provisions of the Development Plan Page 87
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LDP2 format template Nov 2023 Not Applicable (T) Need for notification to Scottish Ministers or Historic Environment Scotland: ☐Yes ☒No Author of Report: Shelley Gould Date: 4/12/25 Reviewing Officer: Sandra Davies Date: 4/12/25 Fergus Murray Head of Development & Economic Growth Page 88
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LDP2 format template Nov 2023 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. Page 89
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LDP2 format template Nov 2023 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 90
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LDP2 format template Nov 2023 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 91
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LDP2 format template Nov 2023 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 one month of the date of this decision the applicant shall establish a forum for effective operational communication with the members of the Clyde Fisheries Association. 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. Page 92
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LDP2 format template Nov 2023 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 vessels as is reasonably practicable. Page 93
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LDP2 format template Nov 2023 ADDITIONAL NOTES TO APPLICANT • Please see the consultation response dated 18 October 2024 from the Northern Lighthouse Board (NLB) for the lighting and marking requirements for this site. • The Aquatic Animal Health (Scotland) Regulations 2009 requires the authorisation of all Aquaculture Production Businesses (APB's) in relation to animal health requirements for aquaculture animals and products thereof, and on the prevention and control of certain diseases in aquatic animals. The authorisation procedure is undertaken on behalf of the Scottish Ministers by the Fish Health Inspectorate (FHI) at the Marine Directorate Marine Laboratory. To apply for authorisation for an APB or to amend details of an existing APB or any site that an APB is authorised to operate at, you are advised to contact the FHI as follows: Fish Health Inspectorate, Marine Directorate Marine Laboratory, 375 Victoria Road, Aberdeen, AB11 9DB. Tel: 0131 244 3498; Email: ms.fishhealth@gov.scot • All marine farms, whether finfish, shellfish or algal, are required to apply for a marine licence under Part 4 of the Marine (Scotland) Act 2010. To apply for a marine licence, or to amend details of an existing marine licence (formally Coast Protection Act 1949 – Section 34 consent), please visit the Scottish Government’s website at http://www.gov.scot/Topics/marine/Licensing/marine/Applications where application forms and guidance can be found. Alternatively you can contact the Marine Directorate Licensing Operations Team (MD-LOT) by emailing MD.MarineLicensing@gov.scot; or calling 0300 244 5046. Page 94
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LDP2 format template Nov 2023 COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 24/01382/MFF PLANNING LAND USE AND POLICY ASSESSMENT 1. Introduction 1.1. The Carradale South fish farm was originally consented in 2009 with Carradale North being consented in 2015. This application is for a change of equipment for the existing Carradale North marine fish farm, located in the Kilbrannan Sound approximately 400m off the eastern shore of the Kintyre Penninsula. The proposal would replace the existing 10no 120m circumference pens with 6 x 160m pens in a formation of 3 x 2 along with the slight change in the position of an existing 650 tonne feed barge which would be located to the south of the group on the shore side. The site would continue to be serviced from the company’s existing shore base located at Carradale Harbour. 1.2. With innovation in pen design and with improving design and capacity of support vessels, Mowi has been upgrading pen equipment across Scotland since 2022. There are now 11 Mowi sites operating 160m pens in Scotland with the Carradale farms being the latest sites we propose to transition. The driver for the developments are operational efficiencies and establishing the conditions for improved health and welfare of farm reared salmon. Fewer, larger pens will reduce stocking density (leading to fish health and welfare benefits) in addition to increasing the efficacy of administering any treatments and undertaking farm maintenance activities. No increase in fish production levels is being sought. The applicant has submitted several applications to the Council to upgrade operational fish farm facilities by replacing existing pens with few smaller pens. This allows a lower stocking density without increasing biomass and has associated benefits for health and safety and fish health. It is noted that there is no proposed increase to the biomass for this site which is 2500 tonnes as consented through the CARs license. A sister application has been submitted for the adjacent Carradale South Marine Fish Farm (24/01381/MFF). The applicant has also recently received planning permission to improve shore base facilities at Carradale Harbour (25/00884/PP) as part of a wider generation proposal for the area. 1.3. The proposed development is located approximately 1.8 km north of Carradale village on the western edge of Kilbrannan Sound and east of the Kintyre peninsula. The smaller hamlet of Grogport lies approximately 2.6 km north west of the Site. The site is not located within any areas of local or national designation and is 2.5km from the east Kintyre Local Landscape Area. 2. Planning Policy 2.1. The Development Plan for the determination of this planning application comprises National Planning Framework 4 (NPF4), adopted February 2023, and the Argyll and Bute Local Development Plan 2, adopted February 2024. NPF 4 is based around six overarching spatial principles which the proposed development should align with. These are: • Just transition; • Conserving and recycling assets; • Local living; • Compact urban growth; Page 95
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LDP2 format template Nov 2023 • Rebalanced development; • Rural revitalisation. 2.2. Not all of these principles will be relevant to every development and in relation to the current proposal it is considered that just transition, rural revitalisation, local living and rebalanced development would apply. In terms of rural revitalisation, NPF4 supports development that helps retain and increase the population of rural areas in Scotland. 2.3. The main policy which relates to aquaculture in NPF 4 is Policy 32, however, other policies within this plan are also relevant and need to be considered in the determination of this proposal. With regard to LDP2, Policy 28 is the main aquaculture policy, however, there are also other relevant policies which are listed above against which the proposal requires to be assessed. 2.4. The proposal benefits from general support from the Scottish Government’s National Marine Plan and from NPF4 which together recognise the contribution of the aquaculture sector to the rural economy and which seek to support sustainable economic development. The National Marine Plan and NPF4 both support marine fish farming where it can take place in environmentally sustainable locations, where it does not exceed the carrying capacity of the water body within which it is to be located, and where it does not give rise to significant adverse effects upon nature conservation, wild fish, historic environment or other commercial or recreational water users. 2.5. Whilst not part of the Development Plan, the Council as a public body is required to take authorisation decisions in accordance with the National Marine Plan (NMP) as the proposal extends into the marine environment, unless relevant considerations indicate otherwise. The proposal should be consistent with general policies of the NMP including: GEN 1 – General planning principle; GEN2 – Economic benefit; GEN 3 – Social benefit; GEN 4 – Co-existence – requires consideration that may occur and the likely effect of interaction between inshore commercial fisheries (loss of fishing ground) and marine and coastal recreational activities. GEN 5 Climate change; GEN7 – Landscape/seascape; GEN 9 – Natural Heritage GEN 10 – Invasive non-native species; GEN 11 – Marine Litter; GEN 12 – Water Quality and Resource; GEN 13 – Noise. 2.6. NPF4 Policy 32 refers the National and Regional Marine Plan and notes that proposals will be supported where they comply with the relevant plans. The criteria noted within the NMP policies above are also covered within the Development Plan policies. 2.7. Beyond development plan considerations, in determining the application regard has to be had to the Council’s’ Economic Development Action Plan which identifies aquaculture as an important contributor to the local economy, and to national government economic and sectoral policy, the stated intention of which is to seek to expand the finfish sector substantially to meet internal and export demands and to help sustain direct and indirect employment in rural areas. Page 96
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LDP2 format template Nov 2023 2.8. In addition, one of the proposals contained within the Rural Growth Deal for Argyll and Bute relates to a vision for Argyll and Bute to be the leading region for innovation in marine aquaculture in Scotland, UK and globally, by underpinning sustainable, inclusive business growth through investment in world class marine science and technology. This includes a commitment to a Marine Industry Needs Assessment. This study will provide the evidence base for industry needs to inform future investment outcomes and the potential options available to deliver these outcomes. This will assist in identifying the key priorities for Rural Growth Deal investment and where this should be targeted to support sustainable growth of this sector and set out in the business case for consideration and approval by Scottish Government. 3. Assessment Against Policy Criteria 3.1. NPF Policy 32 relates specifically to aquaculture. It aims to encourage, promote and facilitate aquaculture development whilst minimising adverse effects on the environment. The policy outcomes sought from this policy are: • new aquaculture development is in locations that reflect industry needs and considers environmental impacts; • producers will contribute to communities and local economies; • prosperous finfish, shellfish and seaweed sectors; • migratory fish species are safeguarded. 3.2. In terms of the spatial strategy Policy 32 does not support development in the north and east coast of mainland Scotland. This is in order to safeguard migratory fish species. 3.3. Point (C) of Policy 32 requires consideration of the operational impacts of fish farms and specifically cites a number of criteria which require to be considered. These criteria are also reflected in the Council’s LDP2 which was adopted in February 2024. 3.4. The proposal requires to be assessed against all of the relevant policies contained within the development plan and not just the aquaculture specific ones. There are some parallels between the requirements of the aquaculture policies and other policies within the development plan and these will be highlighted in the assessment of this application. The application will be assessed against the criteria from LDP2 Policy 28 below with other relevant policies from NPF4 and LDP2 referred to where they would apply. Landscape / coastal character, seascape or visual amenity (including Isolated Coast, Wild Land and National Scenic Areas) 3.5. The applicant has submitted a Landscape, Seascape, Visual Impact Assessment for the Carradale Fish Farm Proposed Replacement Pens carried out by Munro Landscape (02.11.2023). The appraisal evaluates the landscape and visual effects the proposed modifications to the Carradale North and Carradale South sites to replace the 20 existing 120m circumference fish pens with 12 160m circumference fish pens with a slight relocation to the east towards deeper water which will see the Carradale North pen grid move approximately 129m and Carradale South move 149m. The Proposed Development would be located within Seascape Character Area 10 - Lower Firth of Clyde (west) and adjacent to the Upland Forest Moor Mosaic Landscape Character Type. The baseline studies confirmed that the Proposed Development would not be located within a designated landscape however the North Arran NSA is located 2.7 km to the east and the East Kintyre APQ lies 2.0 km to the south of the proposed location. Page 97
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LDP2 format template Nov 2023 3.6. The appraisal provides a comparative Zone of Theoretical Visibility (ZTV) illustrating the ‘change’ in visibility resulting from the change in the location of the pens. Within 5 km of the Proposed Development the ZTVs indicates a very narrow band of visibility on Kintyre, with views largely constrained to the eastern slopes and shoreline. Notable locations/receptors with theoretical visibility include the village of Carradale, and the B842 between Cour and Grogport. Visibility is also predicted from short sections of the Kintyre Way and from the summit of Cnoc nan Gabhar (Deer Hill). To the east, from landfall locations on Arran, visibility is indicated as occurring from the coastline and western slopes of the island, notably between Imachar and Whitefarland Point (including the C147 and Arran Coastal Way). Open views from offshore locations across the study area within the Kilbrannan Sound are indicated as occurring. These views of the Proposed Development are predicted to be very similar in extent to the existing Carradale North and South Fish Farms and add only very small areas of new visibility of the fish pens. 3.7. The submitted SLVIA concludes that resulting effects on landscape character associated with the replacement, and minor relocation of the fish pens would result in, at most, negligible effects on the character of the seascape and landscape. These effects are not significant and ultimately reversible. There would also be no significant effects on landscape designations within the study area to the Proposed Development, including the North Arran NSA and the East Kintyre APQ. Effects on all designations within the study area resulting from the Proposed Development would be at most negligible. These effects are ultimately reversible. The SLVIA concludes: During the operational phase there would be no direct effects on landscape features or elements which define landscape character types or contribute to the special qualities of landscape designations. All effects on landscape character types and designations would be indirect and non-significant in nature only, the assessment determining that in comparison with the existing fish pens the level of effect would be negligible. The level of effect on Lower Firth of Clyde (west) SCA would also be negligible.” 3.8. In terms of visual effects, 5 viewpoints were selected to aid the assessment of this issue. The viewpoints and the reason for their selection are noted in the table below: View point number Viewpoint Name Reason for selection Distance to the Proposed Development 1 B842 north of Grogport The viewpoint is representative of the views available for road users of the B842 road, and cyclists on the NCR 78, north of Grogport, at a promoted picnic are within the Plateau Moor and Forest LCT 39, and the Port Raoin Mhor to Sgeir Bhuidhe Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. 3km 2 Cnoc nan Gabhar (Deer Hill) The viewpoint is representative of the views available for recreational receptors at a hill top location, within the Plateau Moor and Forest LCT 39. 1.9km 3 Culcreuch Road, Carradale The viewpoint is representative of the views available for residential 2.2 km Page 98
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LDP2 format template Nov 2023 receptors, on Culcreuch Road, Carradale within the Coastal Glens LCT 36, and the Port na Cuile to Port Raoin Mhor Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the Area of Panoramic Quality (LLA). 4 Carradale Harbour The viewpoint is representative of the views available for recreational receptors at Port Crannaich, Carradale Pier, within the Coastal Glens LCT 36, and the Port na Cuile to Port Raoin Mhor Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the Area of Panoramic Quality (LLA). 2.2km 5 Imachar Point, Arran The viewpoint is representative of the views available for recreational receptors on the Arran Coastal Way, south of Imachar, within the Raised Beach Coast and Cliffs LCT 59, and the Loch Ranza to South Machrie Bay Seascape Character Area within the Lower Firth of Clyde (West) Seascape Character Area 10. The viewpoint is located within the North Arran National Scenic Area and Special Landscape Area. 4.7km 3.9. In consideration of the degree of change to the existing view that the Proposed Development would constitute the predicted magnitude of change arising from the Proposed Development would be negligible. The visual effects on visual amenity experienced by people in Carradale would be negligible, non-significant, long-term (reversible) and adverse. 3.10. Visual impacts on tourists, or those participating in recreation activities, may be brief in nature by passing through the area on boat, ferry, horse, foot, bike or kayak, their sensitivity to landscape and visual change is high because their purpose/activity is to appreciate landscape and surroundings. The visual assessment has considered views from recreational receptors within 10 km of the Development focusing on those within 5 km radius of the Proposed Development within the detailed study area. Nearby recreation receptors within the detailed study area of the Development include the National Cycle Route NCN 78 and the Kintyre Way long distance footpath on Kintyre. On Arran, the Arran Coastal Way falls within the detailed study area where it passes close to Imachar. Page 99
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LDP2 format template Nov 2023 3.11. The visual assessment has also considered the potential visual effects likely to be experienced by people travelling through the landscape on the local road network. Views will vary depending on proximity to the road, the mode of transport, the angle of view, and intervening landscape features. Potential visual receptors falling within the detailed study area included residents, including those in the village of Carradale and the hamlet of Grogport, in addition to users of the B842 on Kintyre and C147 on the Isle of Arran. Recreational routes falling within the study area include the Kintyre Way, the Arran Coastal Way and National Cycle Route 78. A number of core paths were also identified, these principally comprising a network of paths around Carradale but also forming sections of the Kintyre Way or following the B842. There are also a number of Core Paths within the Study Area, and the following have been identified as wholly or partially falling within the detailed study area: • C094(b) – Tayinloan – Carradale East West Link; • C093(b) - Carradale Forest circular; • C403 - Port na Cuile - Seneval Wood, Carradale; • C097(b) - Carradale Bay circular; • C088(c) - Campbeltown to Cloanaig • AR81 – Coirein Lochan. 3.12. For visual receptors, the Proposed Development, predominantly as a result of the very minor relocation of the pens to the east but also as a result of changes to the size and number of pens, would very slightly change the views people experience. In comparison to the views of the existing pens, the Proposed Development would result in a negligible effect in views from Carradale and no effect from Grogport. In views from transport and recreational routes, both on Kintyre and the Isle of Arran, the Proposed Development would similarly result in a negligible effect on visual amenity. In all cases these effects would be non-significant and reversible. 3.13. In conclusion, there would be no significant seascape, landscape effects and visual effects arising as a result of the Proposed Development in comparison to the degree of change associated with the replacement pens and the existing fish pens to Carradale North and South. It is concluded that the Proposed Development would not result in significant effects on landscape / seascape character and visual amenity. 3.14. The proposal would therefore be in accordance with aquaculture policies 32 d (i) (NPF4), Policy 28 – Supporting Sustainable Aquatic and Coastal Development, LDP2 Policy 4 – Sustainable Development and LDP2 Policy 8 – Sustainable Siting. The natural, built and / or historic or archaeological sites and their settings 3.15. In terms of Marine Cultural Heritage, Historic Environment Scotland has confirmed there are no marine or terrestrial heritage assets within their statutory remit within the development site boundary or within its vicinity 3.16. In addition to policy 28 of LDP2 this would also accord with LDP2 policies 15 and 19. This element of the proposal would also accord with NPF 4 policies 7 and 32. Designated sites, habitats and species for nature conservation (including Priority Marine Features, wild migratory salmonids and European Protected Species). 3.17. Policy 4 of NPF4 Natural Places seeks to ensure that Natural Places are protected and restored. This policy specifically refers to European sites. LDP2 polices 73 and 74 are relevant to this proposal. Policy 73 relates to development impact on habitats, species and biodiversity while Policy 74 relates specifically to sites of international importance. Page 100
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LDP2 format template Nov 2023 The aquaculture specific policies within NPF4 (policy 32) and LDP2 (Policy 28) also require consideration of these issues. 3.18. The proposal is not located within any nationally designated sites. However, reducing the impact of sea lice on wild migratory salmonids is a key element of the current Kilbrannan Sound Environment Management Plan (EMP) secured under the extant consent (20/01345/MFF) and the submitted documentation sets out a number of commitments by the applicant to manage sea lice impacts as follows: • Mowi is committed to compliance with the on-farm sea lice management threshold levels and set out in the Industry Code of Good Practice. This is achieved by applying strategic treatments / interventions, aimed at minimising the numbers of sea lice on farmed fish, and prioritising control during the wild smolt migration period. Mowi’s sea lice intervention strategy is based on the early (within 7 days) treatment of the very first individual pens rather than the later treatment of whole farms. • Mowi will manage its farms in the EMP Management Area in accordance with the Statement of Operational Practice as set in Annex B to minimise the impact of farming activity on wild salmonids. • Within EMP Management Area all three fish farms will be stocked synchronously with Atlantic salmon smolts. 3.19. Impacts on wild migratory salmonids are further managed through the provisions in the current EMP which sets out a wild fish monitoring strategy for the wild salmonid populations in Carradale Water and Endrick Water, under the direction of the Argyll Fisheries Trust and the Argyll District Salmon Fisheries Board. This strategy aims to produce data on the health of wild salmonid populations, within a zone of thirty kilometres from the fish farms located in the EMP Management Area and assess the available nursery habitat utilisation and levels of recruitment of juvenile salmonid fish in the middle and upper reaches of the Endrick Water (from Craigbell weir to Loup of Fintry). 3.20. As part of the wild fish monitoring programme for Carradale Water, Argyll Fisheries Trust undertook fish population surveys at seven sites in Autumn 2023 to assess the status of juvenile salmon and trout populations. These surveys update a time-series of data collected in 2005 and 2009, with proposed annual monitoring to develop a longer- term data set on the health of juvenile salmonid populations in the waterbody. The EMP monitoring has continued in 2025 at the locations shown below, and is completed annually, under the agreed monitoring plan with findings to be shared with the Council in line with the EMP once available: • Carradale Water Estuary - Sea Lice Monitoring • Fish Population Survey - Carradale, Glen Lussa, Machrie Water • Endrick-Blane Water - Electrofishing • Clyde Estuary - sea lice monitoring in the Clyde Estuary at Dumbarton 3.21. Mowi has also developed a sea lice connectivity model for the EMP Management Area and wider waters to simulate the distribution of farm derived sea lice to inform farm to farm infection risk and adaptive implementation of sea lice interventions. This modelling will help to gain a better understanding of the areas where wild salmonids may be vulnerable to infection pressure and inform monitoring locations. Mowi will also support appropriately designed acoustic tracking studies with the aim of addressing information gaps associated with the migration of salmon smolts. 3.22. These programmes are likely to be continued through any National Sea Lice Monitoring Framework to be implemented by SEPA. Page 101
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LDP2 format template Nov 2023 3.23. In accordance with the Predator Control Plan, observations of wildlife and interactions with the fish farm, including entanglement events, will be recorded and reported to Council and NatureScot every 6 months. Acoustic Deterrent Devices (ADDs) have the potential to disturb cetaceans, however, the applicant has committed to not using ADDs and this application has been assessed on this basis. A condition is proposed preventing the use of ADDs. 3.24. The proposal would accord with LDP2 Policy 73 – Development impact on Habitats, Species and Biodiversity and LDP2 Policy 4 – Sustainable Development due to the proposed mitigation for sea lice and the commitment to undertake wild fish monitoring and adaptive management if required. Biodiversity enhancement 3.25. NPF 4, Policy 3 – Biodiversity requires developments to contribute positively to biodiversity enhancement. Given the nature and land ownership constraints of marine fish farming operations, it is not always feasible to provide direct on-site benefits. However, in this instance, the applicant is considering additional biodiversity enhancement which may implemented as part of the Carradale Shorebase landscape and biodiversity enhancement strategy. The applicant is also collating a portfolio of biodiversity enhancement projects across Scotland (including native tree plantation on Skye and projects to improve smolt survival in the River Awe catchment). 3.26. A condition is proposed requiring an update to be submitted on these projects, to the satisfaction of the planning authority. Taking account of the above, it is considered that the proposal would also accord with NPF4 Policy 3 relating to biodiversity enhancement. Ecological status of coastal and transitional water bodies and biological carrying capacity (water quality & seabed impacts). 3.27. The site is operating with a CAR license (SEPA reference: CAR/L/1131788) and SEPA has confirmed no objection to the proposed changes to the operation of this site. Following the submission of further information, SGMD have advised that they have no objection to the proposals and there is no requirement for any further assessment regarding impacts to the water column regarding water column impact. 3.28. Subject to compliance with SEPA’s requirements it is considered that the proposal would comply with Policy 59 – Water Quality and the Environment. Commercial and recreational activity (including other coastal/marine users (MOD)), and navigational interests (including anchorages). 3.29. With regards to anchorages, The Royal Yacht Association (YHA) advised they have no objections to the proposal. As such it is concluded that there would be minimal impacts on recreational marine vessels within the local area. The proposal will not present adverse navigational safety issues, subject to navigational marking to satisfy Northern Lighthouse Board requirements and an informative has been attached to secure this. 3.30. With regards to the impact on commercial fisheries, there have been 11 objections submitted by local fishermen and a sustained objection by The Clyde Fishermen’s’ Page 102
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LDP2 format template Nov 2023 Association which is the membership body for 40 commercial fishing vessels within the Clyde. This sustained objection is despite ongoing dialogue between the applicant and the CFA (please see all representations provided in full in the Report of Handling Section C), the submission of a Moorings Technical Analysis Report, subsequent changes to reduce the proposed mooring area and the submission of a commercial fisheries impact report. 3.31. In terms of the impact of local fishing boats to access local fishing grounds, further moorings design modelling was undertaken by the applicant which subsequently confirmed the ability to reduce the indicative moorings boundary by 250m on the deep water, eastwards side. In addition, the moorings boundary to the west of Carradale south was adjusted eastwards by 56m, to facilitate improved access for creel fishermen (in response to concerns raised by the CFA) on the inshore side of the fish farm. The total development area (including moorings) for the original proposals subject to screening, was 0.826km2 for Carradale North, and 0.818km2 for Carradale South. Following consultation and the above revised technical moorings analysis, revised plans have been submitted which reduce the extend of the mooring areas to 0.471km2 for Carradale North, and 0.471km2 for Carradale South. A reduction of 13% compared to moorings area presented in the originally submitted planning applications and approximately 95% of the supplied AIS (fishing vessel) tracks are now out with the proposed mooring development areas. The applicant notes that any potential displacement effect would be minor compared to the present baseline position, with two operational fish farms in place. 3.32. In addition to developing embedded site design mitigation to allow continued access to fishing grounds and avoid (or reduce) displacement effects to commercial fishing the applicant has committed to a number of operational mitigation measures to prevent conflict with commercial fishing and to promote and facilitate fishing with and in close proximity to the site: • Following site installation, the installed mooring anchor coordinates will be shared with local fishing vessels/CFA and the relevant fisheries representative bodies to allow bottom trawling to be undertaken as close to the mooring infrastructure as safely possible. • If appropriate and subject to other navigational considerations and approvals Mowi is content to provide for enhanced navigational markers for the anchor locations to the east of the fish farms to develop a safe transit-trawling corridor past the sites. • Following installation, the majority of the area taken up by the mooring lines for each development proposal will still be accessible for static gear fishing with full exclusion only required during maintenance of mooring lines or boat operations. Mowi would be willing to work with potting (creeling) vessels to allow and mark safe access and deployment of creels within the mooring’s footprint of the development sites. • Mowi would be willing to work with the CFA to improve communications and liaison with local commercial fishing vessels on farming operations and activities (such as equipment installation) and to provide a mechanism whereby areas of conflict could be discussed and resolved. 3.33. To inform future discussions, the applicant has commissioned a Commercial fisheries impact assessment from a revised pen layout at the Carradale fish farm Phase 1 Report – Desktop Evaluation (October 2025). This Phase 1 report uses published information and AIS records to characterise commercial fisheries in the project area in order to identify and scope potential interactions with the farm infrastructure and operations. The report finds that the proposed farm location is located just north of Carradale on the western side of the Kilbrannan Sound within ICES rectangle 40E414. It is fished by vessels from two Page 103
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LDP2 format template Nov 2023 Scottish fisheries districts of Ayr and Campbeltown, landing mainly into Tarbert, Carradale, West Loch Tarbert and Troon & Saltcoats. The site bathymetry varies from 66 m to 96 m (Carradale North) and 28 m to 51 m (Carradale South), with the deepest parts of the site to the east. The main farm area appears to lie on an area of gravelly sand. Outside the site, the substrate turns muddier in the deeper water to the east. Around 10,600 t of mainly shellfish are landed from the ICES rectangle 40E4, worth some £25.6 million per annum. This is characterised as follows: • Demersal trawls (691 t): Nephrops dominates (>99%) the catch. These trawl caught Nephrops are mostly landed into Tarbet (255 t), Campbeltown (157 t) and Troon and Saltcoats (139 t); this catch is worth around £4 million. There is a very small catch of the bottom trawled finfish into Tarbert only. • Dredges (178 t): The dredge fishery caught 178 t of scallops in 2023. This is mainly landed in the West Loch Tarbert (96 t), Tarbet (35 t), Campbeltown (25 t) and Carradale (22 t). There are also 46 t of scallops landed into Tarbert from passive gears (apart from creels). • Pots and traps (e.g. creels) (191 t): Nephrops are the major creel-caught species, representing 71% of the catch of this passive gear type. Other target species of creels are brown crab (C. pagarus; 9% of the creel catch), velvet crabs (7%) and lobsters (also 6%). Creel-caught Nephrops are mainly landed into Tarbert (90 t), with 18 t each being landed into Carradale and Campbeltown. 3.34. It should be noted that these figures cover the c. 2,500 km2 of statistical rectangle 40E4 which is bisected by the Kintyre Peninsula, with the eastern side including Kilbrannan Sound to the south and Loch Fyne to the north and that the proposed site’s combined mooring area is just 0.82 km2. In terms of timing, the Nephrops caught by trawl peaks over the summer but the creel fisheries are more evenly spread through the year. The crab and lobster creel fishers tend to land during the second half of the year. Scallops are landed mainly in late summer. 3.35. A vessel activity analysis using mainly AIS data indicates that the proposed site extension is right on the western edge of the mainly north / south (and vice versa) tows of the bottom trawl fishery that extends eastwards across the Kilbrannan Sound. Based on AIS data records over a five year period (2019 – 2024) only nine (1.4%) were within the new proposed planning boundary and four (0.3%) were within the proposed mooring boundary. This suggests that the planning boundary is the effective westward limit of bottom trawling this side of the Kilbrannan Sound. This is around 300 m away from the outermost pens under the current configuration and 225 m from the outermost pens under the proposed configuration. 3.36. The report concludes that the proposed move to the east will not have any significant impact on bottom trawling activities, although there will be very little margin for error in navigation. Although not confirmed, this is also likely to be the case for the smaller scallop dredging fishing in the same area. As most creel boats do not have historical AIS track records but keep private plotter records, crab and lobster creeling is likely to be located in the rocky, shallower water of the western inshore part of the site. Nephrops creeling could take 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. 3.37. The report identifies that further work would need to be conducted to verify these results and where necessary establish the extent of the use of mobile gear to the east of the site (esp. smaller vessels that might not use AIS) and creeling activity in and around the proposed project site. Potential stakeholder groups are identified as the CFA, the Page 104
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LDP2 format template Nov 2023 Scottish Creel Fishermen’s Federation (SCFF) and possibly the West Coast Inshore Fisheries Group. 3.38. The CFA have responded to the commercial fisheries report. They note that with regards to the reduced mooring area achieved through revisions, the relative productivity of even a small area of fishing ground is the most important factor. They also note that the report does not adequately consider the wider economic impacts of the creeling industry to the UK economy. The CFA reiterate their frustration at ‘always being the losing side’ when it comes to sharing marine spaces with other parts of the aquaculture industry. However, it is noted in this occasion that the applicant has engaged comprehensively with the CFA, conducted extensive additional analysis with the intention of minimising this conflict as far as possible by avoiding or minimising potential for conflicts through revised mooring extents and have proposed further operational mitigation measures and ongoing engagement. 3.39. To this end, it is considered that a reasonable compromise on the reduced physical extent of the moorings - grounded in the analysis of the technical moorings report and the commercial fisheries study analysis has been reached and despite the ongoing objection, this is acceptable in terms of maintaining co-existence with an already consented marine fish farm. Planning conditions have been agreed with the CFA and the applicant to secure the operational mitigation and support the establishment of local engagement forums with commercial fishing interests in Kilbrannan Sound to support the principle of co-existence with the local commercial fishing activity. 3.40. Taking account of the above, it is considered that proposal would accord with NPF4 policy 32 and LDP2 Policy 28 where they refer to impacts on other marine users. Amenity, arising from operational effects (waste, noise, light and odour). 3.41. Impacts from marine aquaculture developments can include nuisance and disturbance for local residents, recreational and marine users from lighting, noise and odour associated with the installation and operation of fish farms. The applicant has provided details of proposed mitigation measures (submitted statement: ‘Mitigation of amenity impacts arising from operational effects’ September 2025) that will avoid or reduce potential noise, lighting and odour impacts. These measures are part of the project design (embedded mitigation) and good practice operational measures that would form part of standard planning conditions for any fish farm development. Managing noise impacts 3.42. With regard to noise, the development is located along a section of coastline which is sparsely populated, apart from the village of Carradale which is located 1.8km to the south. It is noted that the operational activity at Carradale Harbour is an existing contributor to background noise levels for residential receptors. 3.43. Implementation of best operational practice measures will eliminate, reduce, or manage any potential noise impacts from operational activities to levels within the limits of background noise, and ensure that they are minimised to ensure there are no likely significant effects from noise disturbance. Embedded project design and best practice management measures include the use of noise insulation on equipment, particularly on the feed barge, and restriction of operational activity to normal operational hours, as far as practicable. 3.44. A number of vessels will continue to support day-to-day operations at the farm throughout various stages of the production cycle. The vessels will undertake routine Page 105
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LDP2 format template Nov 2023 husbandry and maintenance activities, including grading, administering treatments, and harvesting. The reduction in pen units from 20 to 12 that will arise (across the combined fish farm) from the planned developments will result in operational efficiencies. Fewer pen units will require much less overall maintenance, such as net cleaning activity and fewer pen units will also allow the whole farm to be treated in quicker timelines. Overall it is anticipated that there will be a reduction in vessel traffic around the sites and associated activities such as net cleaning which have a noise profile. 3.45. It should be noted that although standard working hours are from 07:00 to 20:00 over 7 days, some operations may be required outside this period for reasons of fish health and welfare. Operations may also need to be undertaken outside of standard working hours due to tidal conditions at the site or as a result of delays caused by poor weather (due to the limited windows in which smolts require to be transported and transferred). Also, during certain periods of the year equipment integral to the production cycle will be required to run overnight (e.g. underwater lighting and aeriation systems). Planning conditions are attached to mitigate the effects of all out of hours operations and ‘Well Boat’ activity and further detail is set out below. Minimising light pollution 3.46. The three main operational light sources are (1) underwater anti-maturation lights placed into pens, (2) night-time operations, particularly involving ‘Well Boats’, and (3) measures set out by NLB to ensure the proposed development is appropriately marked, including navigational lighting. 3.47. At certain times of the fish growth cycle underwater lighting in pens is required for the purposes of preventing salmon maturation. Their window of use is from October to the end of the following March. As they are placed at depth surface glare is limited. Embedded design mitigation includes the use of low intensity lights, their correct downward orientation and shielding to reduce upward surface glare. 3.48. The applicant notes that to manage responsibilities for fish health and welfare it is sometimes necessary to employ ‘Well Boats’ in a 24/7 operation at the site. However, every effort is made during treatment planning and scheduling to minimise treatment times and avoid evening working periods especially in locations with neighbouring sensitivities. Where multiple pens require treatment, ‘Well Boat’ duration at a site can increase. As a result, in winter, with reduced daylight hours it is not always possible to avoid working during the hours of darkness and the use of lighting on these vessels. The applicant recognises this can introduce potential conflict with light sensitive properties nearby and has worked with ‘Well Boat’ operators to apply the following mitigation strategies to avoid the potential for light nuisance from essential night time operations (As per ‘Further supporting information’ Mitigation of amenity impacts arising from operational effects submitted 12.9.2025): • Design and scheduling (where possible) of ‘Well Boat’ based treatments with the aim of avoiding or reducing the frequency and duration of vessel treatment activity on site extending beyond 8pm. • Positioning of ‘Well Boats’ on site, to avoid the pen working area between the vessel and the shore (where practicable). • Reduction in intensity of lighting to minimum specifications required. • Application of shielding/covers to lights to avoid directional glare away from the working area. • Switching off lights when not required, for instance for the duration of treatments once fish have been loaded on the vessel. Page 106
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LDP2 format template Nov 2023 • Education, working with operators to understand light sensitive areas and the need for operational efficiencies in use of lights and positioning of the vessel. • Review and identification of options for temporary, less sensitive, positioning locations for ‘Well Boats’ away from farms once fish have been loaded for treatment. 3.49. Navigational Lights and Marks are prescribed by the International Association of Lighthouse Authorities, who class the navigational light (Special Mark) currently on site as ‘minor lights’ with a nominal range of 2 nautical miles. The Northern Lighthouse Board have advised they would require an additional Special Mark for the proposed development, so that the outer corner of the pen moorings grid is indicated. These lights flash yellow once every 5 seconds (off more than on). The feed barge displays an all- round white light (this is the same light that a vessel at anchor must display). While navigation lights are essential for safe navigation mitigations strategies to avoid potential nuisances, include proper placement, maintenance, shielding and education on their requirement with marine and local stakeholders. Odour & waste management 3.50. With regard to waste, a Fish Waste Management Plan (July 2024) is currently in place for the Carradale site and will remain in place. This contains provisions to ensure the development will be kept tidy and any rubbish found on the adjacent shoreline is collected on a regular basis to minimise the impacts of marine litter. This is consistent with NPF4 Policy 12 and LDP2 Policy 63. 3.51. Odours from fish farms are generally associated with fish feed and storage of mortalities. Feed will be stored within sealed silos inside the proposed feed barge negating the risk of fugitive emissions associated with feed storage. Fish mortalities will be collected in a cone located at the bottom of each pen and retrieved using an integrated lift-up system. Site staff will aim to remove mortalities from the base of the pen on a daily basis and three times a week as a minimum. Stock mortalities removed from the pens will be stored in sealed containers for disposal at a licensed facility. 3.52. There will be no net increase in overall biomass as part of the proposed developments arising and no increase in volume of waste produced is anticipated. There will be no material change to existing processes dealing with mortality disposal in the farm management area. 3.53. In relation to well boat operations, the applicant has agreed to provide proactive notification of fish movements (i.e. delivery and collection of smolts) to the Council a year in advance to facilitate monitoring of any amenity impacts. This will be secured by planning condition. It is acknowledged that the tidal nature of this site is a limiting factor and may along with instances or poor weather, occasionally result in well boat use out of normal operating hours. However, it is best operational practice to ensure fish loading and harvesting happens during daylight hours to minimise amenity impacts as far as practicable. 3.54. It is considered that the impacts on amenity would be acceptable and would not conflict with LDP2 Policy 14 – Bad Neighbour Development, NPF 4 Policy 32 or LDP2 Policy 28. LPD2 Policy 29 – Existing Fish Farm Consolidation and Rationalisation requires that redundant equipment be removed from sites to manage waste impacts. A condition is therefore proposed to this effect. Net economic impact, including local community socio-economic benefits such as employment, associated business and supply chain opportunities. Page 107
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LDP2 format template Nov 2023 3.55. NPF4 identifies the significant contribution aquaculture makes to the Scottish economy, particularly for coastal and island communities. It also recognises that changes in economic activity have potentially greater impacts on communities in rural Scotland than more populated areas. The applicant has submitted further information which details how Mowi Scotland activity supports Scotland’s rural employment levels which allows traditional settlement patterns and land use activities to be maintained and helps to sustain local rural services. 3.56. It is further noted by the applicant that fish farming is uniquely placed to deliver actions that will contribute to Argyll and Bute Council’s Economic Strategy and the focus areas of People, Place, Planet and Prosperity with the company’s Argyll based operations contributing to social and economic objectives. Examples showing how we are contributing to social and economic benefits to the Kintyre peninsula are provided throughout this response, including the following: • An existing community fund is in place for the operation of the Carradale Fish Farms with Mowi contributing on an annual basis. • Mowi, in partnership with Salmon Scotland and other farming companies, are working with UHI Argyll to develop and deliver an Aquaculture SCQF4 academic qualification with the practical classroom base elements to be delivered in Campbeltown, Lochgilphead and Oban High Schools. Afterwards the students will then be placed on work experience with a producer company. • Mowi, has entered into a 3 year arrangement with the Campbeltown Picture House to support the community operations and services provided Employment 3.57. In terms of employment, the Carradale fish farms and the nearby Mowi North Kilbrannan fish farm, consented in 2024, and also serviced from Carradale harbour provide 16 direct jobs. The total number of direct jobs provided by Mowi across Argyll and Bute is 75. The average basic salary of those employed by Mowi in the area is £35,059. The Carradale fish farms have been established since 2009. In that time, they have been successful operations from an economic, environmental, and social viewpoint. No new jobs will be provided by the development proposals however the investment in this new larger pen and net technology will future proof operations and employment levels ensuring that the fish farms continue to be successful as fish farming in Scotland evolves. The sector directly supports 540 jobs in Argyll and Bute, with local fish farms sites forming an important part of the economy of rural communities. Annual Operational Expenditure 3.58. Annual Operational Expenditure The cumulative operational annual expenditure for the Carradale fish Farms in 2024 was £15M Within this figure, key local expenditures include labour (£739k), repair and maintenance (£131k), other direct costs (£523k) and indirect costs (£235k); a total of £1.63 million in 2024. Expenditure including feed, health and insurance are not sourced locally, although may contribute to the wider national economy. In 2024 Mowi, across all operations, spent over £14.5million directly with local suppliers and service providers based in the Argyll and Bute council area. Proposed Capital Expenditure Arising from the Development Proposals 3.59. The total capital expenditure for the development proposals for the Carradale North and South fish farms, incorporating the new equipment, comprising 12 x 160m pens, 12 x fish nets and 2 x moorings grids and associated components is approximately £3.35 million. Page 108
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LDP2 format template Nov 2023 Carradale Harbour Development Projects 3.60. Following the recent commencement of fish farming operations at North Kilbrannan and recognising the additional investment proposed for the Carradale fish farms, Mowi is Mowi Scotland Limited, Farms Office, Glen Nevis Business Park, Fort William PH33 6RX Registered in Scotland No. 138843 progressing a number of infrastructure improvement projects in Carradale harbour, due to enhanced business needs. These will be delivered in parallel with community benefit elements developed in consultation with the local community with the shared aspiration to re-energise and improve the harbour environs. The developments proposed include the following elements: • A pontoon for Mowi small personnel craft and defined local community boat owners is proposed and has secured planning consent. • A new shorebase for Mowi’s shoreside services and staff facilities is being developed in the former (now remediated) scrap yard with a planning permission recently granted. • A renovation plan is being developed for the locally important and former (fire damaged) Pier House and gardens, to bring the property back into residential use. • A new community harbour building-facility will be provided by Mowi. The type of building, use and location are being informed by a community consultation exercise with the preferred option to be identified in partnership with the community. Economic Value of Aquaculture to Argyll and Bute 3.61. Aquaculture is an important part of the Scottish Marine economy. In 2022, aquaculture generated £337 million aGVA, 0.20% of the Scottish economy and 7% of the marine economy aGVA. Aquaculture employed 2,200 people, 0.08% of Scottish employment and 3% of marine economy employment. Of this, Atlantic (Scottish) salmon production accounted for 96 per cent of all aquaculture value to the economy.1 Scottish salmon is the UK's top food export, with sales worth £844 million in 2024. Exports of Scottish salmon from the Argyll and Clyde regions rose to £125 million last year as demand for Scottish salmon continues to grow. 3.62. Given the above information it has been demonstrated that the proposed development would have a positive economic impact in accordance with NPF4 Policy 25 – Community wealth Building and NPF4 Policy 29 – Rural development which are supportive of rural economic activity. The proposal would also accord with LDP2 Policy 28, the aquaculture specific policy which requires the economic contribution of aquaculture proposals to be assessed. Potential benefits of sustainable site management proposals, which seek to mitigate or reduce environmental risk from fish farming operations, including escapes, disease and sea lice management and manage risk from fish farming operations, including escapes, disease and sea lice management or manage risk through adaptive management in response to environmental monitoring. 3.63. The applicant notes the proposal to use fewer, larger pens than currently utilised at Carradale is intended to benefit containment, sea lice management and fish health by lowering the stocking density, improving water flow, and aiding the response, speed and efficacy of management intervention. A number of documents have been submitted to support the application and detail operational approaches to adaptive management of environmental risks: • Annex 3 Equipment Attestation Page 109
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LDP2 format template Nov 2023 • Annex 4 Containment and Escapes Contingency Plan and Moorings Technical Report • Annex 5 Sea Lice Management, Efficacy and Attestation • Annex 6 Waste Management Plans • Annex 7 Predator Mitigation Plan • Annex 9 Seascape, Landscape and Visual Assessment (Munro Landscape (02.11.2023). • Kilbrannan Sound Environmental Management Plan (February 2024) 3.64. In terms of sea lice management and the control of risk, the applicant notes that effective sea lice management is a critical requirement to protect the health and welfare of farmed fish and to minimise the risk of potential adverse impacts on wild salmonids. The submitted material notes that poor management of sea lice not only generates environmental impacts, but also a significant cost, primarily through compromised fish health and performance. The applicant’s submitted supporting information entitled ‘Annex 5: Sea Lice Management, Efficacy and Attestation’ sets out its policies and aims for sea lice management, before detailing the operational approach and resources that have been implemented and applied at Carradale North and Carradale South marine fish farms during previous cycles. It is noted that an integrated approach is used to meet regulatory and industry guideline treatment thresholds for sea lice as well as the stricter operational intervention thresholds that Mowi aspires to meet. The document also provides an overview of other relevant fish health management procedures. 3.65. In addition, an Environmental Management Plan (EMP) is in place for Kilbrannan Sound. This commits to monitoring and reporting of lice burdens on farmed and wild fish, a framework for cooperation and transparency and a framework for adaptive management with feedback management measures to be taken in response to evidence of negative impacts on wild salmonids. As of 1 November 2025, SEPA has taken regulatory control of sea lice interactions, with the proposed introduction of a national monitoring framework. A planning condition has been attached to require an update of the EMP should the monitoring framework mechanisms be revised. 3.66. SEPA and SGMD have no objections to the proposals and a CAR permit is in place as part of SEPA’s regulatory framework to manage environmental controls for marine fish farms (SEPA reference: CAR/L/1131788). 3.67. It is considered that the proposal would comply with this element of LDP2 Policy 28 and NPF Policy 32. The applicant has submitted supporting documents detail how the development will be operated to minimise environmental risks and use mitigation and monitoring where appropriate. Proposed operational measures which can mitigate or minimise the level of risk of potential impacts (including on other aquatic or coastal interests). 3.68. NPF4 Policy 1 aims to encourage, promote and facilitate development that addresses the global climate and nature crises while NPF 4 Policy 2 is supportive of developments which have been sited and designed to adapt to current and future risks from climate change. It is noted that marine aquaculture is seen as possible solution to global food shortages that are predicted to increase as a result of climate change. Wild Atlantic salmon is not a sustainable food source. 3.69. However, the industry has also been vulnerable to the effects of temperature rises caused by climate change as evidenced by increased levels of mortalities. Marine fish farms in off-shore locations are also more vulnerable to the effects of storm events which Page 110
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LDP2 format template Nov 2023 are increasing as a result of climate change. However, the Scottish Government Marine Directorate are satisfied with the details of the equipment provided by the applicant. Equipment attestations and specifications have also been provided by the manufacturer which state that the equipment has been designed in accordance with the Norwegian standard to withstand the environmental conditions at the development location. 3.70. A number of documents have been submitted by the applicant in relation to the operation of the site (see above). These include: Escapes Contingency Plan, Farm Management Statement, Predator Mitigation Plan; and Farm Waste Management Plan. The applicant has also provided a self-attestation to confirm that the proposed equipment to be used is suitable for this site and an amended Moorings Technical Analysis Report which details the inputs and results from a full technical dynamic analysis for the revised pen and mooring system design, confirming compliance with applicable equipment design requirements. Adherence to these matters will be secured through the use of planning conditions. 3.71. Subject to these conditions being complied with the proposal will accord with NPF 4 Policy 32 – Aquaculture and LDP2 Policy 28 – Supporting Sustainable Aquatic and Coastal Development. Page 111
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LDP2 format template Nov 2023 APPENDIX B – LIST OF CONTRIBUTORS OBJECTIONS 1. James Anderson, Office, 110 Sound Of Kintyre, Campbeltown, PA28 6GA A further 11 proforma objection letters have been submitted by the following signatories: 2. James Anderson, No address provided 3. Vytoldas Medeikis, No address provided 4. John C Galbraith, No address provided 5. David Anderson, No address provided 6. James Coats, No address provided 7. L Ferguson, No address provided 8. Alasdair MacLean, No address provided 9. S Prentice, No address provided 10. Paul McAllister, No address provided 11. A Hamilton, No address provided 12. John Brown, No address provided Page 112
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© Crown Copyright and database right 2025 All rights reserved. OS license (customer) account number AC0000849384 Location Plan relative to; 24/01382/MFF O 0 570 1,140285 Meters Application Site Page 113
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Ref: ABH1/2009 ARGYLL AND BUTE COUNCIL PROCEDURE NOTE FOR USE AT HYBRID DISCRETIONARY HEARING HELD BY THE PLANNING, PROTECTIVE SERVICES & LICENSING COMMITTEE 1. Hybrid meetings are those that will involve a physical location and facilitate attendees joining virtually if they wish. 2. The Executive Director with responsibility for Legal and Regulatory Support will notify the applicant, all representees, supporters and objectors of the Council’s decision to hold a Hearing and to indicate the date on which the hearing will take place. The hearing will proceed on that day, unless the Council otherwise decides, whether or not some or all of the parties are represented or not. Statutory consultees (including Community Councils) will be invited to attend the meeting to provide an oral presentation on their written submissions to the Committee, if they so wish. Details on how interested parties can access the meeting will be referenced within the same notification. 3. On receipt of the notification the applicant, all representees, including supporters and objectors will be encouraged to appoint one or a small number of spokespersons to present their views to concentrate on the matters of main concern to them and to avoid repetition. Parties who wish to speak at the meeting shall notify Argyll and Bute Council no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting. This is to facilitate remote access (see note 1) and the good conduct of the meeting. 4. The Executive Director with responsibility for Legal and Regulatory Support will give a minimum of 7 days’ notice of the date and time for the proposed Hearing to all parties. 5. The hearing will proceed in the following order and as follows. 6. The Chair will introduce the Members of the Committee, confirm the parties present who have indicated their wish to speak and outline the procedure which will be followed. It is therefore imperative that those parties intending to speak join the meeting at its commencement. 7. The Executive Director with responsibility for Development and Economic Growth’s representative will present their report and recommendations to the Committee. Page 115
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Ref: ABH1/2009 8. The applicant will be given an opportunity to present their case for approval of the proposal and may include in their submission any relevant points made by representees supporting the application or in relation to points contained in the written representations of objectors. 9. The consultees, supporters and objectors in that order (see note 1), will be given the opportunity to state their case to the Committee. 10. All parties to the proceedings will be given a period of time to state their case (see note 3). In exceptional circumstances and on good cause shown the Committee may extend the time for a presentation by any of the parties at their sole discretion. 11. Members of the Committee only will have the opportunity to put questions to the Executive Director with responsibility for Development and Economic Growth’s representative, the applicant, the consultees, the supporters and the objectors. 12. At the conclusion of the question session the Executive Director with responsibility for Development and Economic Growth’s representative, the applicant, any consultees present, the supporters and the objectors (in that order) will each be given an opportunity to comment on any particular information given by any other party after they had made their original submission and sum up their case. 13. If at any stage it appears to the Chair that any of the parties is speaking for an excessive length of time he/she will be entitled to invite them to conclude their presentation forthwith. (see note 3) 14. The Chair will ascertain from the parties present that they have had a reasonable opportunity to state their case. 15. The Committee will then debate the merits of the application and will reach a decision on it. No new information can be introduced after the Committee begins to debate. 16. The Chair or the Governance Officer on his/her behalf will announce the decision. 17. A summary of the proceedings will be recorded by the Committee Services Officer. NOTE (1) If you wish to speak at the hearing you will require to notify the Committee Services Officer no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting. This is to facilitate remote access if required and the good conduct of the meeting. Page 116
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Ref: ABH1/2009 In the event that a party wishes to speak to a visual presentation, this requires to be sent to Committee Services no less than 2 working days (excluding public holidays and weekends) before the commencement of the Hearing; this will not be shared with other parties prior to the meeting but will ensure its availability for the commencement of the Hearing. The Committee Services Officer will control the slides under explicit instruction from the spokesperson(s), it would therefore be helpful if the slides were individually numbered. It would also be helpful if the file size of the presentations is kept to a minimum to mitigate against any potential IT issues – guidance can be provided if required. If it is your intention to join the hearing to observe the proceedings, please advise the Committee Services Officer no less than 2 working Days (excluding public holidays and weekends) prior to the start of the meeting to facilitate remote access if required. (2) Councillors (other than those on the Committee) who have made written representations and who wish to speak at the hearing will do so under note 1 above according to their representations but will be heard by the Committee individually. (3) Recognising the level of representation the following time periods have been allocated to the parties involved in the Hearing. For the avoidance of doubt the time allocated will be per party and will include for example all supporters/objectors in the half hour slot except where additional time is agreed by the Chair. The representative of the Executive Director with responsibility for Development and Economic Growth – not more than half an hour The Applicant - not more than half an hour. The Consultees - not more than half an hour. The Supporters - not more than half an hour. The Objectors - not more than half an hour. (4) The purpose of the meeting is to ensure that all relevant information is before the Committee and this is best achieved when people with similar views co-operate in making their submissions. (5) Everyone properly qualified as a representee recorded on the application report who wishes to be given an opportunity to speak will be given such opportunity subject to the requirements for notice herein. (6) Should, for any reason, Members of the Committee who are joining remotely lose connection or have any technical issues during the meeting, they will be asked to contact the Governance or Committee Support officer, if possible, by email or instant message. A short adjournment may be taken to try and resolve the connection. If the Members of the Committee are unable to re-join the meeting and a quorum still exists then the meeting will continue to proceed. If a Page 117
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Ref: ABH1/2009 quorum does not exist the meeting will require to be adjourned. For the avoidance of doubt Members of the Committee have to be present for the whole hearing in order to take part in the decision. (7) Should, for any reason, participants joining the hearing remotely lose connection or have any technical issues during the meeting, a short adjournment may be taken to try and resolve the connection. In the event the connection cannot be restored within a reasonable timeframe consideration will be given to the continuation of the meeting. (8) Members of the Committee joining remotely will use the hands up function to indicate to the Chair when they wish to speak to ask a question or make a comment. This function will be monitored by the Chair and by governance staff in attendance. (9) Where a Councillor who is a member of the PPSL has made or wishes to make a representation (on behalf of any party) during the meeting in relation to the application under consideration, they should make their position clear to the Chair and declare an interest. Having done so, they may, at the appropriate time, make the relevant representation and then must retire fully from the meeting room prior to deliberation of the matter commencing. A Councillor, not a member of the PPSL, may make a representation (on behalf of any party) during the meeting in relation to the application then must retire fully from the meeting room prior to deliberation of the matter commencing. (10) The Council has developed guidance for Councillors on the need to compose a competent motion if they consider that they do not support the recommendation from the Executive Director with responsibility for Development and Economic Growth which is attached hereto. I:data/typing/virtual planning hearings/procedure note Page 118
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Ref: ABH1/2009 COMPETENT MOTIONS • Why is there a need for a competent motion? o Need to avoid challenge by “third party” to local authority decision which may result in award of expenses and/or decision being overturned. o Challenges may arise from: judicial review, planning appeal, ombudsman (maladministration) referral. Expenses may be awarded against unsuccessful parties, or on the basis of one party acting in an unreasonable manner, in appeal/review proceedings. • Member/Officer protocol for agreeing competent motion: o The process that should be followed should Members be minded to go against an officer’s recommendation is set out below. • The key elements involved in formulating a competent motion: o It is preferable to have discussed the component parts of a competent motion with the relevant Member in advance of the Committee (role of professional officers). This does not mean that a Member has prejudged the matter but rather will reflect discussions on whether opinions contrary to that of professional officers have a sound basis as material planning considerations. o A motion should relate to material considerations only. o A motion must address the issue as to whether proposals are considered consistent with Adopted Policy of justified as a departure to the Development Plan. Departure must be determined as being major or minor. o If a motion for approval is on the basis of being consistent with policy reasoned justification for considering why it is consistent with policy contrary to the Head of Development and Economic Growth’s recommendation must be clearly stated and minuted. o If a motion for approval is on the basis of a departure from policy, reasoned justification for that departure must be clearly stated and minuted. Consideration should be given to holding a PAN 41 Hearing (determined by policy grounds for objection, how up to date development plan policies are, volume and strength of representation/contention) o A motion should also address planning conditions and the need for a Section 75 Agreement. o Advice from the Scottish Government as contained within Planning Circular 3/2013: Development management procedures on the definition of a material planning consideration is attached herewith However, interested parties should always seek their own advice on matters relating to legal or Page 119
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Ref: ABH1/2009 planning considerations as the Council cannot be held liable for any error or omission in the said guidance. Page 120
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Ref: ABH1/2009 DEFINING A MATERIAL CONSIDERATION 1. Legislation requires decisions on planning applications to be made in accordance with the development plan (and, in the case of national developments, any statement in the National Planning Framework made under section 3A (5) of the 1997 Act) unless material considerations indicate otherwise. The House of Lord’s judgement on City of Edinburgh Council v the Secretary of State for Scotland (1998) provided the following interpretation. If a proposal accords with the development plan and there are no material considerations indicating that it should be refused, permission should be granted. If the proposal does not accord with the development plan, it should be refused unless there are material considerations indicating that it should be granted. 2. The House of Lord’s judgement also set out the following approach to deciding an application: - Identify any provisions of the development plan which are relevant to the decision, - Interpret them carefully, looking at the aims and objectives of the plan as well as detailed wording of policies, - Consider whether or not the proposal accords with the development plan. - Identify and consider relevant material considerations for and against the proposal, and - Assess whether these considerations warrant a departure from the development plan. 3. There are two main tests in deciding whether a consideration is material and relevant: - It should serve or be related to the purpose of planning. It should therefore relate to the development and use of land, and - It should fairly and reasonably relate to the particular application. 4. It is for the decision maker to decide if a consideration is material and to assess both the weight to be attached to each material consideration and whether individually or together they are sufficient to outweigh the development plan. Where development plan policies are not directly relevant to the development proposal, material considerations will be of particular importance. 5. The range of considerations which might be considered material in planning terms is very wide and can only be determined in the context of each case. Examples of possible material considerations include: - Scottish Government policy, and UK Government policy on reserved matters - The National Planning Framework - Scottish planning policy, advice and circulars - European policy - A proposed strategic development plan, a proposed local development plan, or proposed supplementary guidance Page 121
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Ref: ABH1/2009 - Guidance adopted by a Strategic Development Plan Authority or a planning authority that is not supplementary guidance adopted under section 22(1) of the 1997 Act - A National Park Plan - The National Waste Management Plan - Community plans - The Environmental impact of the proposal - The design of the proposed development and its relationship to its surroundings - Access, provision of infrastructure and planning history of the site - Views of statutory and other consultees - Legitimate public concern or support expressed on relevant planning matters 6. The planning system operates in the long term public interest. It does not exist to protect the interests of one person or business against the activities of another. In distinguishing between public and private interest, the basic question is whether the proposal would unacceptably affect the amenity and existing use of land and buildings which ought to be protected in the public interest, not whether owners or occupiers of neighbouring or other existing properties would experience financial or other loss from a particular development. Page 122