2401382MFF Carradale North_PPSL Supplementary Report
Argyll and Bute Council · 17 December 2025
Back to Planning, Protective Services and Licensing Committee — 17 December 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Classification: OFFICIAL 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.
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Classification: OFFICIAL 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
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Classification: OFFICIAL 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
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Classification: OFFICIAL 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
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Classification: OFFICIAL 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.
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Classification: OFFICIAL 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.
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Classification: OFFICIAL 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.
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Classification: OFFICIAL 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
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Classification: OFFICIAL 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.
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Classification: OFFICIAL 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