Public reports pack
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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Argyll and Bute Council Comhairle Earra-Ghàidheal Agus Bhòid Executive Director: Douglas Hendry Kilmory, Lochgilphead, PA31 8RT Tel: 01546 605522 DX 599700 LOCHGILPHEAD 10 December 2025 NOTICE OF MEETING A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be held BY MICROSOFT TEAMS on WEDNESDAY, 17 DECEMBER 2025 at 10:30 AM, which you are requested to attend. Douglas Hendry Executive Director BUSINESS 1. APOLOGIES FOR ABSENCE 2. DECLARATIONS OF INTEREST 3. MINUTE (Pages 3 - 16) Planning, Protective Services and Licensing Committee held on 18 November 2025 4. MACLEOD CONSTRUCTION LTD: ERECTION OF 8 DWELLINGHOUSES AND FORMATION OF VEHICULAR ACCESS: LAND EAST OF KNOCK FARMHOUSE, UPPER LOCHGAIR (REF: 22/00680/PP) (Pages 17 - 52) Report by Head of Development and Economic Growth 5. 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 53 - 94) Report by Head of Development and Economic Growth 6. 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 95 - 136) Report by Head of Development and Economic Growth Public Document Pack
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7. JOINT PUBLIC HEALTH PROTECTION PLAN 2025-2027 (Pages 137 - 202) Report by Executive Director with responsibility for Regulatory Services REPORTS FOR NOTING 8. UPDATE ON RECENT TAYNUILT BESS APPEAL (Pages 203 - 208) Report by Head of Development and Economic Growth 9. LOCAL DEVELOPMENT PLAN 3 - EVIDENCE REPORT STAGE ENGAGEMENT (Pages 209 - 214) Report by Executive Director with responsibility for Development and Economic Growth Planning, Protective Services and Licensing Committee Councillor John Armour Councillor Gordon Blair (Chair) Councillor Jan Brown Councillor Audrey Forrest Councillor Kieron Green (Vice-Chair) Councillor Amanda Hampsey Councillor Daniel Hampsey Councillor Graham Hardie Councillor Fiona Howard Councillor Mark Irvine 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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MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE held BY MICROSOFT TEAMS on TUESDAY, 18 NOVEMBER 2025 Present: Councillor Kieron Green (Chair) Councillor John Armour Councillor Jan Brown Councillor Audrey Forrest Councillor Graham Hardie Councillor Fiona Howard Councillor Andrew Kain Councillor Paul Donald Kennedy Councillor Dougie Philand Councillor Peter Wallace Attending: Fergus Murray, Head of Development and Economic Growth Shona Baron, Governance Manager Peter Bain Development Manager Kirsty Sweeney, Area Team Leader – Helensburgh & Lomond/Bute & Cowal) Tim Williams, Area Team Leader – Oban, Lorn and the Isles Emma Jane, Planning Officer Emma Shaw, Planning Officer Lorna Pearce, Senior Development Officer Kim de Buiteléir, Senior Planning and Strategies Officer 1. APOLOGIES FOR ABSENCE Apologies for absence were received from Councillors Gordon Blair, Amanda Hampsey, Daniel Hampsey and Mark Irvine. 2. DECLARATIONS OF INTEREST There were no declarations of interest. 3. MINUTES a) The Minute of the Planning, Protective Services and Licensing Committee held on 22 October 2025 at 11.00 am was approved as a correct record. b) The Minute of the Planning, Protective Services and Licensing Committee held on 22 October 2025 at 2.30 pm was approved as a correct record. c) The Minute of the Planning, Protective Services and Licensing Committee held on 22 October 2025 at 3.30 pm was approved as a correct record. 4. THE SCOTTISH GOVERNMENT: SECTION 36 CONSULTATION FOR WIND FARM CONSISTING OF 9 TURBINES EACH WITH A MAXIMUM BLADE TIP HEIGHT OF UP TO 180 METRES. GENERATING CAPACITY WILL BE MORE THAN 50MW: KILLEAN ESTATE, NEAR TAYINLOAN (REF: 24/01541/S36) The Development Manager spoke to the terms of supplementary report number 1 which summarised the decision taken by the PPSL Committee on 22 October 2025 to submit a holding objection in respect of this application. The Energy Consents Unit were notified of this and were advised that matters would be considered further by the Committee at this meeting to agree a final response to the ECU. Page 3 Agenda Item 3
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Decision The Committee agreed to object to this proposal for the following reasons and that the Energy Consents Unit be notified accordingly: Argyll and Bute Council objects to the application on the basis of NPF 4 policies 4a and 11 Section E, Paragraphs 2, 3, 4 and 13 and LDP2 Policy 30 on the basis that the application would have a cumulative, significant and unacceptable adverse impact in respect of landscape, visual and cumulative matters. The current application comprises 9 wind turbines up to 180m high to blade tip. The majority of the proposed wind turbines are located within a conifer plantation with three wind turbines lying in more open ground close to the woodland edge. A previous application for a wind farm on the location was refused planning permission. In the Landscape Experts report it is stated – ‘The Landscape and Visual Impact Assessment (LVIA) finds that significant effects would arise on the character of the Upland Forest Moor Mosaic LCT within which the proposed wind farm would be sited. The Members agree with this finding and with the judgement that these effects would extend up to around 6km or so from the wind farm’. It also confirms that the Landscape Expert is of the opinion that the wind farm would incur significant adverse effects on the Coastal Plain LCT which forms a triangular and flat area of farmland, woodland and moor extending west to Rhunahaorine Point. This is a relatively small LCT and effects would be widespread. The expert also disagreed with the judgement made in the LVIA with regard to effects on the character of the Coastal Parallel Ridges LCT which covers the whole of the island of Gigha. Gigha lies less than 3km from the west coast of the Kintyre peninsula at its closest point across the narrow Sound of Gigha. The very large turbines of this proposal would be prominent in views from Gigha and from the Sound of Gigha and I consider that significant adverse effects would occur on the sense of remoteness and naturalness associated with the island and the immediate waters surrounding the island. While Members agree with the Landscape Expert’s opinion that this development will cause a significant adverse impact on the landscape character the Members disagree with the recommendation not to object to the application for the following reasons. The landscape expert lists the following as all significant adverse effects - The Significant Adverse effects are not limited to the local area but cover a large area to the west and in particular, within 1.7km of the West Kintyre Coast Local Landscape Area (LLA)’ ‘and it principally comprises settled and more intricately patterned coastal fringes with key special qualities likely to comprise a diverse landform and landcover pattern and views along the coast and out to sea to the west to Gigha, Islay and Jura.’ Members also agree with the landscape expert’s advice that ‘ that there would be significant adverse effects on some of the key qualities of this LLA’ The landscape expert also states that – ‘The location of the proposed development on west-facing outer slopes of the Kintyre peninsula would increase visibility from the sea, coast and Gigha. I consider that significant adverse effects on views would principally occur from the following locations: Page 4
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The Kintyre Way - where the proposed development would be seen at close quarters as the route is aligned through the development site. The Sound of Gigha and Gigha. - The proposed wind farm would be visible across much of Gigha and the Sound of Gigha. The west Kintyre coast. - There would be extensive visibility of the proposal from the predominantly open Coastal Plain. Knapdale - There would be visibility of the proposed wind farm from the southern part of the Knapdale peninsula with this likely to be restricted to more open coastal locations due to the extensive woodland present. The Islay Ferry - Similar to the account of views from Knapdale above. The landscape expert says that – ‘Changes have occurred to national planning policy since the 2019 Conjoined Killean and Clachaig Glen Wind Farms PLI. NPF4 Policy 11(e) (ii)( states that significant landscape and visual impacts are to be expected for some forms of renewable energy and where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable. NPF4 provides no guidance on the definition of what constitutes ‘localised’ effects. The Killean proposal would have significant adverse effects on landscape and coastal character and on the character of the island of Gigha. Significant adverse effects on views will principally occur from Gigha Sound, from the settled eastern coast and small spine of hills on Gigha, the Kintyre Way and the Rhunahaorine Point/Point Sands area’ Members of the Planning Committee submit that this is not a localised issue as the visual impact will cover an area larger than 9km and as such is contrary to NPF4 Policy 11(e)(ii). The landscape expert goes on- ‘Changes to national planning policy and the consent of the Clachaig Glen II wind farm have a bearing on the decision to be made on the acceptability of this proposal in terms of its landscape and visual effects. While I consider that the effects of this proposal on its own could be termed more than local in extent because of the significant effects on landscape/coastal character and on views from Gigha and the Sound of Gigha that would arise (lying up to 9km distance), the likely construction of the Clachaig Glen II wind farm would moderate these effects. I therefore recommend that no objection should be raised in respect of landscape and visual interests’. Members understand the argument put forward by the Landscape Architect but do not accept that the construction of the Clachaig Glen II windfarm would moderate and as such mitigate the significant impact of this development on the landscape character and visual amenity. ‘Cumulative landscape and visual effects would principally arise between the consented Clachaig Glen II wind farm and this proposal. As there is a strong likelihood that the consented Clachaig Glen II scheme will be constructed, it is important that the Killean proposal is not considered in isolation. In many key views, for example from Point Sands (VP4) and from Gigha (VPs 6 and 8), the Killean proposal will appear as an extension to Clachaig Glen II wind farm, exacerbating significant adverse effects, for example, in terms of increasing the extent of turbines seen on skylines looking east but not being the first to introduce new much larger and more prominent wind turbines to the scene. Put simply, the consent of Clachaig Glen II will already incur significant adverse effects on key views Page 5
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from Gigha, Gigha Sound and part of the west Kintyre coast and this will reduce landscape and visual sensitivity and the magnitude of change likely to occur should the nine turbines of the Killean proposal be added in a similar location.’ Again, Members understand the argument put forward by the Landscape Architect but do not accept that the construction of the Clachaig Glen II windfarm would moderate and as such mitigate the significant cumulative impact of this development on the landscape character and visual amenity. We the Planning Committee disagree with this recommendation not to object on the grounds that the cumulative effect of the two combined wind farms will incur significant adverse effects on key views from Gigha, Gigha Sound and the Kintyre Coast contrary to the above noted development plan policies. In addition, visible aviation lighting would increase the duration of these adverse effects on views. (Reference: Report by Head of Development and Economic Growth dated 6 October 2025 and Supplementary Report Number 1 dated 4 November 2025, submitted) 5. MR KYLE KENNEDY: ERECTION OF DWELLINGHOUSE, FORMATION OF VEHICULAR ACCESS AND ASSOCIATED WORKS: LAND BETWEEN LAGARIE LODGE AND LAGARIE HOUSE, TORWOODHILL ROAD, RHU (REF: 25/00576/PP) The Planning Officer spoke to the terms of the report and to supplementary report number 1 which advised of additional representations received since publication of the main report including a late objection from Rhu and Shandon Community Council. Reference was also made to late representations received from Councillor Maurice Corry and Mr Jim Crawford, which were circulated to the Committee. The site is located within the settlement area of Rhu and lies within the Rhu Conservation Area and the residential property adjacent to the West “Lagarie House” which is a Category “B” listed building. Also within the vicinity is the Category “A” listed “Ardencaple Hotel”. The site is covered by a Tree Preservation Order, however, the site is not located within or in proximity of any nature conservation sites, nor does it lie within NatureScot Ancient Woodland Inventory. In 2023, a planning application (reference 23/01502/PP) for a single dwelling with proposed access from the A814 was submitted along with an accompanying listed building consent application in relation to the formation of the vehicular access through the listed wall (reference 20/0183/LIB). These applications were both approved on 23 May 2024 and remain extant consents. Approval of this planning application for a single dwelling on this application site accepts the principle of development for a single dwelling on this site. Objections have been received from 19 third party representatives. Officers are not recommending a pre-determination hearing as it is considered that there would be no added value as all material considerations have been taken into account within the report, including consultee responses, third party representations and planning history. 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 Page 6
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to indicate that it would be appropriate to withhold planning permission having regard to Section 25 of the Act. It was recommended that planning permission be granted subject to the conditions and reasons detailed in the report of handling. Decision The Committee agreed to grant planning permission subject to the following conditions and reasons: Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction 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 07.04.25; 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. The development shall be implemented in accordance with the details specified on the application form dated 07.04.25; 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 Location Plan 1 of 13 A 9th April 2025 Site Plan as Existing 2 of 13 - 8th April 2025 Site Sections A-A + B-B as existing 3 of 13 A 5th September 2025 Site Sections C- C + D-D as existing 4 of 13 A 5th September 2025 Site Plan as proposed 5 of 13 A 5th September 2025 Site Sections A-A + B-B as proposed 6 of 13 A 5th September 2025 Site Sections C- C + D-D as proposed 7 of 13 A 5th September 2025 Ground Floor Plan as proposed 8 of 13 A 5th September 2025 South West Elevation 9 of 13 A 5th September 2025 Page 7
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North East Elevation as proposed 10 of 13 - 5th September 2025 South East Elevation as proposed 11 of 13 - 5th September 2025 North West Elevation as proposed 12 of 13 A 5th September 2025 Roof Plan as proposed 13 of 13 A 7th November 2025 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. Scottish Water – Notwithstanding Condition 1, Prior to the commencement of development, the developer shall submit written evidence to the Planning Authority that an agreement with Scottish Water is in place for the connection of the proposed development to the public water supply and wastewater sewage network. Reason: In the interests of public health and to ensure the availability of an adequate water supply to serve the proposed development. 3. Sustainable Urban Drainage – Notwithstanding Condition 1, details of a sustainable urban drainage system compliant with the guidance set out in CIRIA’s SuDS Manual C753 must be submitted to and approved in writing by the planning authority prior to the commencement of development. The surface water drainage shall be operational prior to the development being brought into use and shall be maintained as such thereafter. Reason: To ensure adequate surface water drainage is implemented to prevent flooding elsewhere. 4. Landscape - Notwithstanding Condition 1, Prior to the commencement of development, full details of both hard and soft landscape works to be carried out at the site shall be submitted to and approved in writing by the local planning authority in the form of a detailed landscaping plan. The approved hard landscaping works shall be carried out prior to first occupation of the development and the soft landscaping works / replacement tree planting within the first planting season following first occupation of the development. The details submitted shall include: - details of the proposed hard surfacing (including proposed materials); - details of proposed boundary treatments; - details of proposed soft landscaping; - details of the replacement tree planting (location, size and species); - programme for completion and subsequent on-going maintenance. Reason: In the interests of biodiversity and the natural environment. 5. Biodiversity Enhancement - Notwithstanding Condition 1, Prior to the commencement of development, a revised biodiversity statement based on the Preliminary Ecological Assessment table 6 shall be submitted to and approved in writing by the Planning Authority. The statement shall demonstrate how the proposal Page 8
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will contribute to conservation/restoration/enhancement of biodiversity, and how these benefits will be implemented and maintained for the lifetime of the development. All physical biodiversity enhancement measures (bird nesting boxes, ‘swift bricks’, wildlife ponds, bat and insect boxes, hedgehog homes etc) as set out in the Preliminary Ecological Assessment table 6 and also include the retention of any felled native species as deadwood shall be implemented in full before the development hereby approved is first brought into use. All biodiversity enhancement measures consisting of new or enhanced planting shall be undertaken either in accordance with the approved scheme of implementation or within the next available planting season following the development first being brought into use. Reason: To comply with the requirements of NPF4 Policy 3 and the recommendations of the council biodiversity officer. 6. Trees – Notwithstanding Condition 1, Prior to the commencement of development, a tree protection plan shall be submitted to and approved in writing by the authority. Thereafter, all retained trees on site shall be protected at all times during construction in accordance with the British Standard; BS 5837:2012 (Trees in relation to design, demolition and construction – Recommendations). Reason: The landscape features to be protected are important to the appearance and character of the site and the surrounding area and are required to successfully integrate the proposal with its surroundings. 7. Pre-works checks - Notwithstanding Condition 1, Prior to the commencement of development, pre-works checks for the presence of bats, breeding birds, hibernating hedgehogs and amphibians on site; shall be carried out by an appropriately qualified person. In circumstances where species of interest are identified as being present, or at risk from construction works, a statement shall be submitted to and approved by the authority in writing to provide suggested avoidance and or mitigation measures, including timing constraints, to address such presence or risk. Reason: In order to establish that the circumstances of the site have not changed significantly between approval and implementation of the development for the purpose of protecting natural heritage assets in the interest of nature conservation. 8. Invasive Non-Native Species Eradication Plan - Notwithstanding Condition 1, Prior to the commencement of development, a non-native species eradication plan (in accordance with the ‘Code of Practice with regard to non-native species; http://www.scotland.gov.uk/Publications/2012/08/7367/0’) for the non-native species present on site shall be submitted to and approved in writing by the authority. Reason: In the interest of nature conservation. 9. External Materials - Notwithstanding Condition 1, Prior to the commencement of development, samples of the proposed materials to be used for the external finishes of the development hereby approved shall be submitted to and approved in writing by the Planning Authority. Page 9
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Reason: In the interests of visual amenity and in order to integrate the proposal with its surroundings. 10. Sustainable Design – Notwithstanding Condition 1, Prior to the commencement of development, details of the on-site micro renewable energy to provide heat or electricity to the property and details of the use of the final materials – including details of any re-cycled materials or local sourced materials and their embodied energy for each materials, shall first be submitted and approved in writing by the Local Planning Authority. Thereafter the approved micro renewables and materials must be used in the development hereby approved. Reason: In order to ensure compliance with LDP2 Policy 09 and to ensure the building is being as energy efficient as possible in order to respond to climate change. 11. Quality homes – Notwithstanding Condition 1, Prior to the commencement of development, details of the proposed timescale for completion of the approved development have been submitted to and approved by the Planning Authority. Thereafter, the development shall be implemented in accordance with the duly approved timescale for completion unless an alternative timescale for completion is otherwise agreed in writing with the Planning Authority. Reason: In order to comply with the requirements of NPF4 Policy 16F. 12. Potential sources of nuisance – Notwithstanding Condition 1, Prior to the commencement of development, identification and assessment of all potential sources of nuisance, including noise/ vibration, dust, and any temporary lighting provided, which may cause disturbance to nearby residents during the demolition / construction process shall be undertaken by the applicant. This should include consideration of intended hours of operation, movement of vehicles, use of plant and storage of equipment and materials on site. For all potential sources of nuisance, the applicant will be required to provide a management plan with details of suitable control measures to be put in place so as to ensure that construction does not cause loss of amenity to local residents and/or statutory nuisance. The management plan must be submitted to and approved by the Planning Authority and thereafter complied with. Reason: In order to avoid sources of nuisance in the interest of amenity. 13. Parking and Turning – Notwithstanding Condition 1, The parking and turning area shall be laid out in accordance with the details shown on the approved drawing reference; 00-003 REV. A prior to the development first being occupied and shall thereafter be maintained clear of obstruction for the parking and manoeuvring of vehicles. Reason: In the interest of road safety. 14. Junction with public road - Notwithstanding Condition 1, the proposed access shall be formed in accordance with the Council’s Roads Standard Detail Drawing SD 08/005 Rev. B (as laid out on approved drawing reference; 00-003 REV. A) incorporating vehicular visibility splays of 75 x 2.4 x 1.05 metres measured from the edge of the carriageway and pedestrian visibility splays of 2.4 m x 2.4 x 0.9 metres measured from the rear of the footway. Thereafter the driveway shall be formed in accordance with the Page 10
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Council’s Roads Standard Detail Drawing SD 08/002 Rev. B, providing a minimum driveway access width of 5.5m for the first 10m, reducing to no less than 3.7m thereafter (3.5m where not bound by walls). The access shall be surfaced with a bound material for the first 5m. Gradients of the access drive must be no greater than 5% over the first 5.0m and thereafter must not exceed 12.5%. Drainage shall be achieved within the boundary such that no water shall discharge onto the public carriageway. Prior to the commencement of development the access hereby approved shall be formed to at least base course standard and the visibility splays shall be cleared of all obstructions such that nothing shall disrupt the required visibility spays. The final wearing surface on the access shall be completed prior to the development first being occupied and the visibility splays shall thereafter be maintained clear of all obstructions in perpetuity. Reason: In the interests of road safety. Having moved an Amendment which failed to find a seconder, Councillor Fiona Howard asked for her dissent from the foregoing decision to the be recorded. (Reference: Report by Head of Development and Economic Growth dated 11 November 2025, Supplementary Report Number 1 dated 17 November 2025, submitted and late representations received by email, tabled) 6. MR GAETANO GRIEVE: ERECTION OF 4 DWELLINGS, INSTALLATION OF SEWAGE TREATMENT PLANTS AND FORMATION OF 2 VEHICULAR ACCESSES: LAND WEST OF KOMANI AROS MAINS, AROS, ISLE OF MULL (REF: 25/01248/PP) The Planning Officer spoke to the terms of the report. In terms of the adopted Local Development Plan 2 (LDP2), the site is identified as ‘Outwith Settlement Areas’ within an area defined as ‘Countryside Area’ where Policy 02 of LDP2 gives a presumption in favour of sustainable development where it is of an appropriate scale, design, siting and use for its countryside location, as set out in the relevant sustainable siting and design policies of LDP2. A previous application was submitted for the development of the site with six dwellinghouses and associated works. This application was subsequently withdrawn following concerns raised by the Planning Authority with regard to the density and siting of the proposed development. The current application proposes an amended scheme, seeking to address the previous concerns. The proposal has elicited 27 objections, 1 representation and 2 expressions of support. There have been no objections from statutory consultees. Most of the objections relate largely to existing water supplies, the suitability of the access to serve the proposed development, and the visual impact resulting from the proposed development. The application site is not covered by any specific environmental or landscape designations and the Officer’s recommendation is aligned with the consultation responses received from both the Council’s Roads Authority and Scottish Water and as such it is not considered that a pre-determination hearing would add significant value to the decision making process. The proposal is considered to be consistent with the relevant provisions of the Development Plan, and there are no other material considerations of sufficient Page 11
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significance, including issues raised by third parties, to indicate that it would be appropriate to withhold planning permission having regard to Section 25 of the Act. It was recommended that planning permission be granted subject to the conditions and reasons detailed in the report. Decision The Committee agreed to grant planning permission subject to the following conditions and reasons: Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction 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 22.07.2025, 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 Location Plan 677_PL_001 C 28.07.2025 Site Plan – Existing 677_PL_002 28.07.2025 Site Sections – Existing 677_PL_003 A 28.07.2025 Site Plan – Ground Floor 677_PL_010 C 28.07.2025 Site Plan – First Floor 677_PL_011 D 28.07.2025 Site Plan – Roof 677_PL_012 D 28.07.2025 Site Plan – Aerial photomontage 677_PL_013 B 28.07.2025 Site Sections – Proposed 677_PL_020 A 28.07.2025 House Type A1 677_PL_101 C 28.07.2025 House Type A2 677_PL_102 D 28.07.2025 House Type B1 677_PL_103 B 28.07.2025 House Type B variant plans – accessibility study 677_PL_104 23.10.2025 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. 2. Timescale to be Agreed for Completion Page 12
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No development shall commence until details of the proposed timescale for completion of the approved development have been submitted to and approved by the Planning Authority. Thereafter, the development shall be implemented in accordance with the duly approved timescale for completion unless an alternative timescale for completion is otherwise agreed in writing with the Planning Authority. Reason: In order to comply with the requirements of NPF4 Policy 16F. 3. Sustainable Drainage System Notwithstanding the effect of Condition 1, the development shall incorporate a surface water drainage system which is consistent with the principles of Sustainable urban Drainage Systems (SuDS) compliant with the guidance set out in CIRIA’s SuDS Manual C753 and Sewers for Scotland 4th Edition. The requisite surface water drainage shall be operational prior to the development being brought into use and shall be maintained as such thereafter. Reason: To ensure the provision of an adequate surface water drainage system and to prevent flooding. Note to Applicant: Further advice on SuDS can be found in SEPA’s Standing Advice for Small Scale Development – www.sepa.org.uk 4. Junctions with Public Road Notwithstanding the provisions of Condition 1, the proposed accesses shall be formed in accordance with the Council’s Roads Standard Detail Drawing SD08/004b and visibility splays of 25 metres to point X by 2.4 metres to point Y from the centre line of the proposed access. The access shall be surfaced with a bound material in accordance with the stated Standard Detail Drawing. Prior to work starting on site the access hereby approved shall be formed to at least base course standard and the visibility splays shall be cleared of all obstructions such that nothing shall disrupt visibility from a point 1.05 metres above the access at point X to a point 0.6 metres above the public road carriageway at point Y. The final wearing surface on the access shall be completed prior to the development first being brought into use and the visibility splays shall be maintained clear of all obstructions thereafter. Reason: In the interests of road safety. Note to Applicant: • A Road Opening Permit under the Roads (Scotland) Act 1984 must be obtained from the Council’s Roads Engineers prior to the formation/alteration of a junction with the public road. • The access shall be constructed and drained to ensure that no surface water is discharged onto the public road. • Bin storage areas shall be located to the rear of the bay element of the Council’s Roads Standard Detail Drawing SD08/004b. Page 13
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5. Parking and Turning – Further Details Required Notwithstanding the provisions of Condition 1, no development shall commence until full details of the layout and surfacing of parking and turning areas to accommodate two vehicles per dwelling for House Types ‘A1’ and ‘A2’ and three vehicles for House Type ‘B’ within the application site have been submitted to and approved in writing by the Planning Authority in consultation with the Council’s Roads Engineers. The duly approved scheme shall be implemented in full prior to the development first being occupied and shall thereafter be maintained clear of obstruction for the parking and manoeuvring of vehicles. Reason: In the interest of road safety. 6. Landscaping and Biodiversity Enhancement No development shall commence until a scheme of boundary treatment, surface treatment and landscaping has been submitted to and approved by the Planning Authority. The scheme shall include details of: i) Location, design and materials of proposed walls, fences and gates; ii) Surface treatment of proposed means of access and hardstanding areas; iii) Any proposed re-contouring of the site by means of existing and proposed ground levels; iv) Proposed hard and soft landscape works; v) A biodiversity statement demonstrating how the proposal will contribute to conservation/restoration/enhancement of biodiversity, and how these benefits will be maintained for the lifetime of the development; and vi) A management plan for the removal of invasive non-native species, to include a programme of monitoring and maintenance. The development shall not be occupied until such time as the physical biodiversity enhancement measures (bird nesting boxes, ‘swift bricks’, wildlife ponds, bat and insect boxes, hedgehog homes etc), the boundary treatment, surface treatment and any re-contouring works have been completed in accordance with the duly approved scheme. All biodiversity enhancement measures consisting of new or enhanced planting shall be undertaken either in accordance with the approved scheme of implementation or within the next available planting season following the development first being brought into use. All of the hard and soft landscaping works shall be carried out in accordance with the approved scheme during the first planting season following the commencement of the development, unless otherwise agreed in writing by the Planning Authority. The biodiversity statement should refer to Developing with Nature guidance | NatureScot as appropriate. Page 14
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Reason: To assist with the integration of the proposal with its surroundings in the interest of amenity. 7. Electric Vehicle Charging – Residential with off street parking Prior to the commencement of the development (or such other timescale as may be agreed in writing with the Planning Authority), a scheme detailing the provision of four minimum 7kw electric vehicle charging points shall be submitted to and approved in writing by the Planning Authority. Where charging cannot be provided then the appropriate ducting to future proof the property must be installed. The approved charging point, or where relevant, the approved cable ducting shall be installed in full prior to the first occupation of the development, and thereafter retained in perpetuity unless otherwise agreed in writing by the Planning Authority. Reason: To comply with the provisions of NPF4 Policy 13 Sustainable Transport and LDP2 Policy 34 – Electric Vehicle Charging. 8. Offsite Highway Improvements Notwithstanding the provisions of Condition 1 no development shall commence until full details of offsite highway improvements have been submitted to and approved by the Planning Authority in consultation with the Council’s Roads Engineers. Such details shall incorporate: Notwithstanding the provisions of Condition 1 no development shall commence until full details of offsite highway improvements have been submitted to and approved by the Planning Authority in consultation with the Council’s Roads Engineers. Such details shall incorporate: Prior to the dwellinghouses hereby granted being first occupied, the approved scheme of works shall be completed. Reason: In the interest of road safety to provide a standard of access commensurate with the scale of the development. (Reference: Report by Head of Development and Economic Growth dated 4 November 2025, submitted) 7. TARBERT CONSERVATION AREA APPRAISAL AND MANAGEMENT PLAN Consideration was given to a report seeking Member approval to consult on the draft Tarbert Conservation Area Appraisal and Management Plan. Decision The Committee agreed to the consultation of the draft Tarbert Conservation Area Appraisal and Management Plan, noting a consultation period of 6 weeks was proposed, which would run between 5 January and 16 February 2026, with a drop in event planned to be held on 14 January 2026. Page 15
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(Reference: Report by Executive Director with responsibility for Development and Economic Growth dated 17 September 2025, submitted) 8. DEVELOPMENT MANAGEMENT PERFORMANCE UPDATE - FQ2 2025/26 A report providing an update on the performance of the Development Management Service for the reporting period FQ2 2025/26 was considered. Decision The Committee reviewed and agreed the content of the report. (Reference: Report by Executive Director with responsibility for Development and Economic Growth dated 31 October 2025, submitted) The Committee resolved in terms of Section 50(A)(4) of the Local Government (Scotland) Act 1973 to exclude the press and public for the following item of business on the grounds that it was likely to involve the disclosure of exempt information as defined in Paragraph 13 respectively of Part 1 of Schedule 7A to the Local Government (Scotland) Act 1973. 9. EMERGENCY TREE PRESERVATION ORDER Consideration was given to a request for a provisional Tree Preservation Order. Decision The Committee agreed to the recommendation detailed in supplementary report number 1. (Reference: Report by Executive Director with responsibility for Development and Economic Growth and Supplementary Report Number 1 dated 18 November 2025, submitted) Page 16
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 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: 22/00680/PP Planning Hierarchy: Local Applicant: MacLeod Construction Ltd. Proposal: Erection of 8 dwellinghouses and formation of vehicular access. Site Address: Land East of Knock Farmhouse, Upper Lochgair, 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 • Change of use of land to Class 9 Houses • Erection of 8 dwellinghouses • Formation of new vehicular access junction with trunk road • Formation of adoptable access road • Formation of vehicular parking • Surface drainage infrastructure (ii) Other specified operations • Connection to services (B) RECOMMENDATION: Having due regard to the Development Plan and all other material consideration, it is recommended that members approve planning permission subject to the conditions and reasons appended to this report. (C) CONSULTATIONS: SEPA (18th April 2024) – refer to their standing advice. Scottish Water (15th May 2022) – has no objection to the scheme, noting that the site would be served by Ardrishaig Water Treatment Works and Lochgair Waste Water Treatment Works. The Applicant is informed that they must submit a pre-development enquiry to Scottish Water following the granting of any subsequent planning permission to reserve capacity. Page 17 Agenda Item 4
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Transport Scotland (17th May 2022, 2nd July 2024 and 3rd December 2024) – originally sought further information relating to dimensioned access junction plans. Following a series of additional documentation submissions and re-consultations, Transport Scotland confirm within their latest response (3rd December 2024), that they seek further clarification on matters relating to the pedestrian link; visibility height obstruction; a speed survey to demonstrate that a lower SSD is appropriate; and revisions to the crossing layout. (25th July 2025) – following the applicant’s submission of a traffic speed survey and revised plans, Transport Scotland have no objections to the scheme subject to the inclusion of planning conditions to ensure the access is constructed to a layout and type of construction as approved by Transport Scotland, agreement of the details for the pedestrian link and that drainage shall no connect to trunk road drainage systems. Scottish Rights of Way and Access Society (15th February 2024) – do not wish to provide any specific comments on the scheme. Argyll and Bute Council Internal Consultee responses Area Roads Officer (19th May 2022) – has no objections subject to conditions relating to access construction to adoptable standards, sufficient car parking spaces, a pedestrian footway link and restriction of a vehicular link between the new development road and the existing private road. Flood Risk Advisor (23rd May 2022, 10th May 2024 and 6th August 2024)- The Officer originally requested the submission of further information to inform their recommendation relating to a site-specific Flood Risk Assessment. Following receipt of this, the Officer confirms they have no objections to the proposal subject to the inclusion of planning conditions relating to Finished Floor Levels at a minimum height of 0.3m above surrounding ground level as a mitigation measure given the proximity to the modelled surface water flood extents; and that post-development runoff rate should be attenuated to the greenfield runoff rate before discharge from the site. Environmental Health Officer (7th June 2022) – no objections subject to conditions relating restriction on construction hours and restriction on noise levels arising from air source heat pumps to safeguard neighbouring amenity. Environmental Health: Contaminated Land Officer (26th May 2022) – has no objections subject to a planning condition to secure the implementation of a contaminated land phased site investigation and risk assessment. West of Scotland Archaeological Service (15th June 2022) – has no objections subject to the inclusion of a planning condition to secure the implementation of a programme of archaeological works in accordance with a written scheme of investigation. (D) HISTORY: 08/01340/DEP – “Erection of a terrace of four affordable dwelling houses and four (semi- detached) dwelling houses”. Application withdrawn 01.09.2011 10/01847/PP – “Erection of 5 terrace, 4 semi-detached and 1 detached dwelling-houses and formation of access (amended plan)” Application approved 28.11.2013 Page 18
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 12/00898/PP – “Formation of access to service the drainage infrastructure (septic tank) (relative to application reference 10/01847/PP for housing)”. Application approved 28.11.2013 19/01872/PP Erection of 2 dwellinghouses and formation of vehicular access withdrawn 12.01.2021. (E) PUBLICITY: Regulation 20 Advert Local Application expired 10.06.2022 Neighbour Notification expired 30.05.2022 (F) REPRESENTATIONS: (i) Representations received from: At the time of writing, representations have been received from 41 respondents in relation to this planning application. A total of 35 respondents raise objection and 6 respondents provide general comments. The names and addresses of those contributing to the application are contained within Appendix B, and full copies of the representations are published 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: Comments on Policy • Contrary to LDP DM1 as it exceeds “small scale” which is defined as not exceeding 5 houses, within villages and minor settlements. • Council’s allocation appears to support the enlarged application contrary to Lochgair’s size. • No masterplan has been agreed as per previous permission requests • Will set precedence for the development of the remainder of the site with further housing. • Contrary to policies LDP STRAT 1; LDP 3;LDP 9; SG LDP Hou 1; SG LDP ENV 13 • Contrary to both local and national planning policy Officer Comments: An analysis of the proposal against the policies of the Development Plan is contained in full in Appendix A. The application put forward must be considered on the merits of the scheme and determined as such. Local Facilities • Village has no school, no shop, and limited public transportation • Previous applications have not improved the village or enhanced public realm • Village hall has been deemed unsafe and it’s a request that a financial contribution is sought towards the repair and upkeep of the hall as each house is developed. • Village offers no employment Page 19
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Officer Comment: The adopted Development Plan is the relevant statutory document arisen through public scrutiny and relevant to this site and which in its’ making considered matters of planning need / locational bias / and sustainability. It was acknowledged at the time of the Plans’ assessment/adoption that there was no school or shop within the village but the need to zone this land specifically for housing as an ‘allocation’ was identified in the full knowledge of the facts. Housing Design • Modern housing estate design contrast with traditional design of dwellings such as Knock House and Knock Steading. • Proposals do not seem to relate well to the existing properties within Lochgair • Proposed house materials do not take account of traditional stone construction of nearby properties and use of wooden panels is not a feature which is part of the Lochgair vernacular. • Development is out of character with the existing village. Officer Comment: Whilst traditional vernacular characteristics is found within the immediate two neighbouring properties, recognition has also had to be paid to the changing form and characteristics of the original Lochgair as it has extended south toward upper Lochgair which all forms part of the settlement designation as defined within the Local Development Plan and the variations in architectural vernacular, scale and materiality. Scale • There are 21 houses in upper Lochgair; this planning application is for 24 houses this is more than doubling the amount of properties overwhelming the village. • Development would cause overcrowding in a small village • Development is too large for a small village in a rural setting to absorb • Size of the development all be it in an incremental basis appears disproportionate to the established settlement of Lochgair • Density of housing is extreme. Officer Comment: This is a housing allocation which has been considered through the Local Development Plan process. The scale of the development is therefore considered to be acceptable. It should be noted that this application seeks permission for the erection of 8 dwellings. Consideration of any additional housing would be subject to separate planning permissions of which the acceptability of those schemes would be considered under those applications. Affordable Housing • Affordable housing in the outlying villages is a contraction in terms with today’s travel and other costs • Houses will become part time homes • Affordable housing shortfalls were mainly in larger towns and do not quantify demand at village level, therefore need for substantial additional housing in this sensitive location has not been established. • First phase does not include any affordable housing • Indicative affordable housing looks very small • It would seem possible that these houses would be used as holiday homes bringing no benefit whatsoever to Lochgair. Officer Comment: The requirement to establish current ‘need’ cannot be entertained during the assessment of this application for a development on a site specifically Page 20
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 ‘allocated for housing’ through the statutory Local Plan process which itself considered ‘need’ in the deliberations of its’ public assessment/scrutiny/and adoption. Accessibility and Road Matters • Pedestrian access proposes the use of a private road for the seven houses as far as knock steading. The road is poorly constructed, narrow without a footpath or lighting and unsuitable for adoption. • Concern regarding pedestrian safety when using private road. • Adopted road pavement is in poor condition • Insufficient information regarding vehicular access and the safety of the proposed junction. • Who is responsible for maintenance of the private road and who is liable should a pedestrian have an accident • New pedestrian footpath will suddenly terminate at the grass verge on the main road. • Consider a road safety audit should be prepared. • Pedestrian link and amenity space are not within the boundary of this planning application. • A fully accessible, safety pedestrian route into lochgair should be provided before the first house is occupied. • Proposed access is in a dip in the road with reduced visibility and a near a dangerous corner. Even if the current 40 speed limit was extended, cars and large lorries frequently ignore the notices. • Proposal would cause parking issues in the village • Proposal does not include a pavement to the village which would be required for public safety for residents to reach the bus stop. • All residents would have to commute by car to reach public services and amenities. Officer Comment: These matters are considered in full within the committee report. No objections have been received from the statutory consultees on road safety matters subject to the imposition of planning conditions. Regarding the pedestrian link to Upper Lochgair road, this would subject to a separate planning application for detailed planning permission. Flooding • concern regarding increased flooding due to recent felling of commercial forestry above the site. • Site is on boggy ground • Area is frequently waterlogged when it rains. Officer Comment: The application is supported by the necessary technical information on such matters. The Council’s Flooding and Drainage Advisor is content that the submitted details comply with necessary technical standards. Landscape • Proposal is in an area designated as “areas of panoramic quality” and the proposal represents over development of the site; increases in pollution and contamination through noise and lighting; safety issues due to lack of footpaths • Development would negatively impact the attractiveness of Lochgair contrary to the Area of Panoramic quality designation. • The scale and visual impact of the proposals present unacceptable high density and loss of character of the area Page 21
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Officer Comments: Landscape impacts are assessed in full in the Report of Handling in Appendix A. Whilst the site lies within a settlement within an Area of Panoramic Quality, the principle of the site (its location) and the scale of the development is already established through the other aforementioned policies/ issues considered in the same Local Development Plan. To accord with relevant policies, a planning condition is recommended to agree biodiversity enhancement and landscaping to achieve further betterment in terms of materials/ biodiversity/ design detailing. Servicing and Infrastructure • Existing sewage arrangements would be pushed to capacity by a further 26 houses • insufficient information provided to understand the impact on water supply, sewage capacity impacts; Wi-Fi infrastructure; street lighting. • Will lead to intolerable pressure on existing infrastructure of water supply, sewage, traffic and walking paths • water pressure to homes in Lochgair is not particularly good. Additional 8 houses would make this worse. Officer Comment: The application is supported by the necessary technical information on such matters. The Council’s Flooding and Drainage Advisor, SEPA and Scottish Water are content that the submitted details comply with necessary technical standards. Natural Environment Impacts • Contrary to the indication, there are trees on and adjacent to the site • Site is a haven for wildlife and provides essential habitat to support and spread of native species. • Proposal is on a greenfield site Officer Comment: The site is not covered by any specific nature designation. Policy provision allows for the development of greenfield land when it forms part of an allocated site within the Local Development Plan which is the case in this instance. There are trees surrounding the development which would not be directly impacted from the proposal. Biodiversity enhancement measures are recommended to be secured by planning condition to further enhance the biodiversity value of the site in its developed state. Residential Amenity • The development will have an adverse effect on the residential amenity of neighbours, by reason of noise and light pollution due to the additional residents, vehicular access and potential loss of privacy. • Loss of existing open views from neighbouring properties would adversely affect the amenity of neighbouring owners. • Gardens proposed are tiny with no room for a vegetable plot. Officer Comment: The right to a view is not a material planning consideration. Comments from the Environmental Health Officer confirm that subject to planning conditions relating to construction working hours, and operational noise levels of air source heat pumps, the proposal would not adversely affect neighbouring amenity. Procedural matters • Development is Schedule 3 Development as the proposed mass housing would bring crowds into a generally quiet area as will the play park in latter phases; Page 22
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 the proposes mass housing will alter the character of the area; play park will generate noise; and new street lighting will introduce light pollution; and the works include a sewage pumping station and large septic tank installation, • Given the number of objections submitted, a public hearing should be convened in order that those who have taken the time to response are offered the opportunity to state their case before the planning committee. Officer Comments: This application is for 8 dwellings and does not include provision of a playpark. The application is being considered on the details put forward and not therefore on future development which would be subject to their own scrutiny through separate planning applications. The matter of a public hearing is considered in further detail within Section (N) of this report. Planning History and Developer comments • Reference to planning history of the site • Developer has incomplete sites all around Argyll Officer Comments: The application is being considered on the details put forward. (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 The document provides a general outline of the housing requirements for the area, the background to the design, potential designs of houses, amenity provision, affordable housing and general infrastructure. (iv) Sustainability Checklists (with reference to the requirements of LDP2 Policy 04) TN06 Sustainability Checklist TN07 Sustainable Buildings Checklist ☒Yes ☐No ☒Yes ☐No (v) A report on the impact of the proposed development eg. Retail impact, transport impact, noise impact, flood risk, drainage impact etc: ☒Yes ☐No - Flood Report - Speed Survey Report Page 23
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (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 NPF4 Policy 5 – Soils NPF4 Policy 7 – Historic Assets and Places NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings (includes provisions relevant to Greenfield Sites) NPF4 Policy 11 – Energy NPF4 Policy 12 – Zero Waste NPF4 Policy 13 – Sustainable Transport Liveable Places NPF4 Policy 14 – Design, Quality and Place NPF4 Policy 15 – Local Living and 20 Minute Neighbourhoods NPF4 Policy 16 – Quality Homes NPF4 Policy 17 – Rural Homes NPF4 Policy 18 – Infrastructure First NPF4 Policy 22 – Flood Risk and Water Management Argyll and Bute Local Development Plan 2 (Adopted 2024) Spatial and Settlement Strategy Policy 01 – Settlement Areas Policy 04 – Sustainable Development High Quality Places Policy 05 – Design and Placemaking Policy 06 – Green Infrastructure Policy 08 – Sustainable Siting Policy 09 – Sustainable Design Page 24
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Policy 10 – Design – All Development Policy 14 – Bad Neighbour Development Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment Policy 21 – Sites of Archaeological Importance Connected Places Policy 32 – Active Travel Policy 33 – Public Transport Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes Policy 36 – New Private Accesses Policy 37 – Development Utilising an Existing Private Access or Existing Private Road Policy 38 – Construction Standards for Public Roads Policy 39 – Construction Standards for Private Accesses Policy 40 – Vehicle Parking Provision Sustainable Communities Policy 55 – Flooding Policy 61 – Sustainable Urban Drainage Systems (SUDS) Policy 62 – Drainage Impact Assessments Policy 63 – Waste Related Development and Waste Management Homes for People Policy 64 – Housing Development on Allocated Sites Policy 67 – Provision of Housing to Meet Local Needs Including Affordable Housing High Quality Environment Policy 71 – Development Impact on Local Landscape Areas (LLA’s) Policy 73 – Development Impact on Habitats, Species and Biodiversity Policy 79 – Protection of Soil and Peat Resources Policy 82 – Contaminated Land Policy 83 – Safeguarding Agricultural and Croft Land Local Development Plan 2 Schedules (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 draft Technical Note – Argyll and Bute Windows (April 2018) • TN06 Sustainability Technical Note and Checklist (Oct. 2023) • TN21 VII and LVIA Light Technical Note (Oct. 2023) • TN07 Sustainable Buildings Technical Note and Checklist (Oct. 2023) • ABC Landscape Studies • ABC Housing Needs and Demand Assessment • ABC Housing Emergency Statement • SEPA Standing Guidance for Development Management (Dec. 2022) Page 25
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (K) Is the proposal a Schedule 2 Development not requiring an Environmental Impact Assessment: ☒Yes ☐No Screening Opinion attached at Appendix C. (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 A total of 41 public representations have been received in response to this planning application. 35 objections and 6 respondents raise concern. A representation has also been received from Cllr Dougie Philand whom requests a pre-determination hearing is undertaken. Consideration therefore requires to be given to the benefits of holding a pre-determination hearing. Although the application conforms with the housing allocation conferred by the local development plan, the application does raise issues relating to the intended means of access to the site and road safety, to which sufficient information has been submitted to allow a full assessment of this material planning consideration. It is the opinion of the Planning Authority that the representations received, together with the Officer assessment of the relevant planning issues contained within this report, provide all the information required to enable Members to make an informed decision based on all the material planning considerations in this case. It is therefore, not considered that the objections raise any complex or technical issues that have not been addressed in the Report of Handling, and it is not considered that a discretionary local hearing would add value to the planning process. (O)(i) Key Constraints/Designations Affected by the Development: • West Loch Fyne (Coast) Local Landscape Area • Right of Way/174 Code – 138174 Rights of Way • A83 (buffer = 67m) Trunk Roads • Mid Argyll SEPA Flood Zones (Surface Water) • SEPA Waste Water Drainage Consultation Areas • SPR Paths - 30 October 2008 SPR Paths • Aspiration Paths - 5th March 2014 (O)(ii) Soils Agricultural Land Classification: Class 5.2 Improved Grassland Peatland/Carbon Rich Soils Classification: ☐Class 1 ☐Class 2 ☐Class 3 ☒N/A Peat Depth Classification: N/A Page 26
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Does the development relate to croft land? ☐Yes ☒No Would the development restrict access to croft or better quality agricultural land? ☐Yes ☐No ☒N/A Would the development result in fragmentation of croft / better quality agricultural land? ☐Yes ☐No ☒N/A (O)(iii) Woodland Will the proposal result in loss of trees/woodland? (If yes, detail in summary assessment) ☐Yes ☒No Does the proposal include any replacement or compensatory planting? ☐Yes ☐No details to be secured by condition ☒N/A (O)(iv) Land Status / LDP Settlement Strategy Status of Land within the Application ☐Brownfield ☐Brownfield Reclaimed by Nature ☒Greenfield ABC LDP2 Settlement Strategy ☒Settlement Area ☐Countryside Area ☐Remote Countryside Area ☐Helensburgh & Lomond Greenbelt ABC LDP2 Allocations/PDAs/AFAs etc: Site H3029. Allocated for housing. Covering 1.92ha and to accommodate 26 units. (P) Summary assessment and summary of determining issues and material considerations The application is for planning permission for a residential development on a site allocated for housing within the adopted Argyll and Bute Local Development Plan (2024). The principle of residential development has therefore been established by the site’s allocation (ref.H3029). The proposed development would look to develop part of the allocated site with 8 detached, residential units according with Development Plan policies on all material planning considerations apart from road safety. On the matter of road safety, sufficient information has now been submitted with the application to demonstrate that the proposed access junction with the A83 trunk road meets Design Standards as required by the Trunk Road Authority subject to planning conditions. At the time of writing, public representations had been received by the Planning Authority from 41 respondents in relation to this planning application with 31 objecting to the scheme and the remaining respondents raising concern. Road safety is a key concern of the public representatives. The proposal accords with the policy provision of the adopted National Planning Framework 4 and Local Development Plan 2 and it is recommended that planning permission be approved subject to conditions. A full report is provided in Appendix A. Page 27
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 (Q) Is the proposal consistent with the Development Plan: ☐Yes ☒No (R) Reasons why Planning Permission Should be Approved: 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 in principle 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 Author of Report: Laura MacDonald Date: 27.11.2025 Reviewing Officer: Peter Bain Date: 04.12.2025 Fergus Murray Head of Development & Economic Growth Page 28
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 22/00680/PP Standard Time Limit Condition (as defined by Regulation) Standard Condition on Soil Management During Construction 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 31/03/2022, 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 Location Plan 4724/101 01/04/2022 Site Plan 4724/102 J 18/07/2025 Longitudinal Section along A83 showing visibility heights 4724/117 D 15/07/2025 Proposed Floor Plans Plot 1 4724/103 01/04/2022 Proposed Elevations Plot 1 4724/104 01/04/2022 Proposed Floor Plans Plot 2 4724/105 01/04/2022 Proposed Elevations Plot 2 4724/106 01/04/2022 Proposed Floor Plans Plot 3 4724/107 01/04/2022 Proposed Elevations Plot 3 4724/108 01/04/2022 Proposed Floor Plans Plot 4 4724/109 01/04/2022 Proposed Elevations Plot 4 4724/110 01/04/2022 Proposed Floor Plans Plot 5 and 7 4724/111 01/04/2022 Proposed Elevations Plot 5 and 7 4724/112 01/04/2022 Proposed Floor Plans Plot 6 and 8 4724/113 01/04/2022 Proposed Elevations Plot 6 and 8 4724/114 01/04/2022 Fence/Heat pump details 4724/115 01/04/2022 Reason: For the purpose of clarity, to ensure that the development is implemented in accordance with the approved details. Page 29
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 2. PP – Affordable housing with Commuted Sum option Notwithstanding the effect of Condition 1, no development shall commence until a scheme for the provision of affordable housing (as defined below) has been submitted to and approved in writing by the Planning Authority. The scheme shall: a) Provide that a minimum of 25% of the approved dwellings are affordable homes; b) Define those properties to be used as affordable homes; c) Establish the timing of their provision relative to the phasing of the development, which shall ensure that the last 25% of the dwellings within the development are not commenced until the affordable housing phase has bene completed for occupation; d) Establish the arrangements to ensure the affordability of the affordable homes for both initial and subsequent occupiers (including any discount rate applicable in terms of (ii) below); OR e) Alternatively, shall provide for an equivalent Commuted Sum Payment to the Council’s Strategic Housing Fund having regards to the report ‘Valuation of Commuted Sum Payments’ approved by Argyll and Bute Council on 27th June 2013. For the purposes of this condition ‘affordable homes’ are defined as being either: i) Social housing (rented or shared ownership or shared equity) managed by a registered social landlord (a body registered under part 3 chapter 1 of the Housing (Scotland) Act 2001, or any equivalent provision in the event of the revocation and re-enactment thereof, with or without modification); ii) Discounted low cost sale housing (subject to a burden under the Title Conditions (Scotland) Act 2003), or any equivalent provision in the event of the revocation and re-enactment thereof, with or without modification). iii) Housing for sale or rent without subsidy, which is designed to be affordable and to meet the housing needs of the majority of those households identified as in housing need in the Local Housing Strategy or Housing Market Study i.e. one or two person households on average income, with conditions attached to their missives to prevent further extension, thereby helping to ensure that they are likely to remain affordable to subsequent purchasers. The development shall be implemented and occupied thereafter in accordance with the duly approved scheme for affordable housing. Reason: To accord with the provisions of the development plan in respect of affordable housing provision. 3. PP – Landscaping No development shall commence until a finalised scheme of boundary treatment; surface treatment and landscaping has been submitted to and approved by the Planning Authority. The scheme shall comprise a planting plan and schedule which shall include details of: i) Existing and proposed ground levels in relation to an identified fixed datum; ii) Existing landscaping features and vegetation to be retained; iii) Location design and materials or proposed walls, fences and gates; Page 30
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 iv) Proposed soft and hard landscaping works including the location, species, and size of every tree/ shrub to be planted; v) A programme for the timing, method of implementation, completion and subsequent ongoing maintenance for all planting vi) A biodiversity statement demonstrating how the proposal will contribute to the conservation/ restoration/ enhancement of biodiversity, and how these benefits will be maintained for the lifetime of the development. The development shall not be occupied until such times as the boundary treatment, surface treatment and any re-contouring works have been completed in accordance with the duly approved scheme. All of the hard and soft landscaping works shall be carried out in accordance with the approved scheme during the first planting season following the commencement of the development, unless otherwise agreed in writing by the Planning Authority. Any trees/shrubs which within a period of five years from the completion of the approved landscaping scheme fail to become established, die, become seriously diseased, or are removed or damaged shall be replaced in the following planting season with equivalent numbers, sizes and species as those originally required to be planted unless otherwise approved in writing by the Planning Authority. The Biodiversity Statement should refer to Developing with Nature Guidance, NatureScot as appropriate. Reason: To assist with the integration of the proposal with its surroundings in the interest of amenity, and to comply with the requirements of NPF4 Policy 3. 4. PP – Footpath link No development or site clearance works shall commence, for the development hereby permitted, until detailed planning permission has been granted for the footpath link outwith the red line boundary as indicated on the approved Site Plan drawing number “4724/102 Revision J”. Reason: to ensure that facilities are provided for the pedestrians that are generated by the development and that they may access the existing footpath system without interfering with the safety and free flow of traffic on the A83 trunk road. 5. PP – Junction with Public Road Prior to the commencement of the development, the proposed access on the A83 trunk road, as generally illustrated by the approved site plan, drawing number “4724/102 Revision J”, shall be constructed to a layout and type (and method) of construction to be approved by the Planning Authority, in consultation with Transport Scotland. Reason: To ensure that the standard of access layout complies with the current standards and that the safety of the traffic on the trunk road is not diminished. 6. PP – Trunk Road Drainage system There shall be no drainage connections to the trunk road drainage system. Reason: to ensure that the efficiency of the existing drainage network is not affected. Page 31
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 7. PP – Internal layout access Notwithstanding the provisions of Condition 1, the proposed accesses to the new adoptable standard development road shall be formed in accordance with the Council’s Roads Standard Details; and visibility splays of 25 metres to point X by 2.4 metres to point Y from the centre line of the proposed access. The access shall be surfaced with a bound material in accordance with the stated Standard Detail Drawing. Prior to work starting on site the access hereby approved shall be formed to at least base course standard and the visibility splays shall be cleared of all obstructions such that nothing shall disrupt visibility from a point 1.05 metres above the access at point X to a point 0.6 metres above the public road carriageway at point Y. A dropped kerb crossing point shall be provided at each access with the access surfaced for a distance of 5 metres from back of footway. The final wearing surface on the access shall be completed prior to the development first being brought into use and the visibility splays shall be maintained clear of all obstructions thereafter. Reason: In the interests of road safety. 8. PP – Construction Hours Notwithstanding the provisions of Condition 1, the construction of the development hereby permitted shall be restricted to the specified hours of 0800-1800 hours Monday to Friday, 0800 – 1300 hours Saturday and not at all on Sunday, Bank or Scottish Public Holidays unless otherwise agreed in writing by the Planning Authority. Reason: To minimise the impact of noise, generated by construction activities on occupiers of residential properties. 9. PP – Parking and Turning The provision of parking and turning for the development hereby permitted, shall accord with the requirements of Policy 40 and Table 5 of the Argyll and Bute Local Development Plan 2 2024. Reason: to ensure an adequate number of vehicle parking spaces to meet development needs. 10. PP- Finished Floor levels Notwithstanding the provisions of Condition 1, the finished ground floor levels of the dwellings, hereby permitted, shall be at least 0.3m above surrounding ground level, unless otherwise agreed in writing by the Planning Authority. Reason: in order to ensure appropriate mitigation for flood risk and to ensure an acceptable relationship between the development and its surroundings. 11. PP – Runoff Rate The post development runoff rate should be attenuated to the greenfield runoff rate before discharge from site. Any drainage at the site should be designed in accordance with CIRIA C753. Reason: in the interests of flood risk prevention. Page 32
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 12. PP – Programme of Archaeological Works No development shall take place within the development site, as outlined in red on the approved plan until the developer has secured the implementation of a programme of archaeological works in accordance with a written scheme of investigation which has been submitted to and approved in writing by the Planning Authority in consultation with the West of Scotland Archaeological Service. Thereafter the developer shall ensure that the programme of archaeological works is fully implemented and that all recording and recovery of archaeological resources within the development site is undertaken to the satisfaction of the Planning Authority in consultation with the West of Scotland Archaeological Service. Reason: In order to comply with the requirements of NPF4 Policy 16F. 13. PP – ASHP Noise limits The noise level from the operation of the air source heat pumps hereby approved must not exceed 42dB LAeq (5 min) at 1 metre from the window of a habitable room on the façade of any neighbouring residential property. If, in the opinion of the Local Planning Authority the proposed air source heat pumps result in any noise nuisance to the occupant of any neighbouring dwelling the Applicant shall install noise mitigation measures in agreement with the Planning Authority. Reason: To ensure that the residential amenities that occupiers can reasonably expect to enjoy are adequately protected. 14. PP – Contaminated Land Assessment No development, demolition or ground-breaking works shall commence until a scheme is submitted by the Developer (at their expense) to identify and assess potential contamination on site and approved, by the Planning Authority, and is thereafter implemented in accordance with the scheme so approved. The scheme shall be undertaken by a competent person or persons in accordance with relevant authoritative guidance including PAN 33 (2000) and BS10175:2011 or, in the event of these being superseded or supplemented, the most up-to-date version(s) of any subsequent revision(s) of, and/or supplement(s) to, these documents. This scheme should contain details of proposals to investigate and remediate potential contamination to the satisfaction of the Planning Authority, and must include:- a) A desk study and development of a conceptual site model including (where necessary) a detailed site investigation strategy. The desk study and the scope and method of recommended further investigations shall be agreed with the Council prior to addressing parts b, c, and d of this condition. Should the desk study show the need for further assessment this will be undertaken in the following sequence: a) A detailed investigation of the nature and extent of contamination on site, and assessment of the risks such contamination presents. b) Development and agreement of a remedial strategy (if required) to treat/ remove contamination ensuring the site is made suitable for its proposed use (this shall include a method statement, programme of works, and proposed verification plan). Page 33
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 c) Submission of a verification report for any agreed remedial actions detailing and evidencing the completion of these works. Written confirmation from the Planning Authority, that the scheme has been implemented and completed shall be required by the Developer before any development hereby approved commences. Where remedial measures are required as part of the development construction detail, commencement must be agreed in writing with the Planning Authority. Reason: To ensure that the potential risks to human health, the water environment, property, and, ecological systems arising from any identified land contamination have been adequately addressed. 15. PP – Arrangements for Waste No development shall commence until a waste strategy detailing how much waste the proposal is expected to generate and detailing the arrangements for the storage, separation and collection of waste from the site, including provision for the safe pick up by refuse collection vehicles, have been submitted to an approved in writing by the Planning Authority. Thereafter the duly approved provision shall be implemented prior to the first occupation of the dwellings which it is intended to serve. Reason: In order to ensure that satisfactory arrangements have been made for dealing with waste on the site in accordance with NPF4 Policy 12. 16. PP – Materials No development shall commence until full details /samples of materials to be used in the construction of the dwelling houses hereby approved have been submitted to and approved in writing by the Planning Authority. The development shall thereafter be completed using the approved materials or such alternatives as may be agreed in writing with the Planning Authority. Reason: In order to integrate the development into its surroundings. 17. PP – Restriction of PD Rights Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (Scotland) Order 1992 (as amended), (or any Order revoking and re- enacting that Order(s) with or without modifications), nothing in Article 2(4) of or the Schedule to that Order, shall operate so as to permit, within the area subject of this permission, any development referred to in Part 1 and Classes 1A, 1B, 1C, 1D, 2A, 2B, 3A, 3AA, 3B, 3C, 3D and 3E and Part 2 and Classes 8 and 9 of the aforementioned Schedule, as summarised below: PART 1: DEVELOPMENT WITHIN THE CURTILAGE OF A DWELLINGHOUSE Class 1A: Any enlargement of a dwellinghouse by way of a single storey ground floor extension, including any alteration to the roof required for the purpose of the enlargement. Class 1B: Any enlargement of a dwellinghouse by way of a ground floor extension consisting of more than one storey, including any alteration to the roof required for the purpose of the enlargement. Class 1C: The erection, construction or alteration of any porch outside any external door of a dwellinghouse. Class 1D: Any enlargement of a dwellinghouse by way of an addition or alteration to its roof. Page 34
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Class 2A: The erection, construction or alteration of any access ramp outside an external door of a dwellinghouse. Class 2B: Any improvement, addition or other alteration to the external appearance of a dwellinghouse that is not an enlargement. Class 3A: The provision within the curtilage of a dwellinghouse of a building for any purpose incidental to the enjoyment of that dwellinghouse or the alteration, maintenance or improvement of such a building. Class 3AA: The provision within the curtilage of a dwellinghouse of a building for any purpose incidental to the enjoyment of that dwellinghouse. Class 3B: The carrying out of any building, engineering, installation or other operation within the curtilage of a dwellinghouse for any purpose incidental to the enjoyment of the dwellinghouse. Class 3C: The provision within the curtilage of a dwellinghouse of a hard surface for any purpose incidental to the enjoyment of that dwellinghouse or the replacement in whole or in part of such a surface. Class 3D: The erection, construction, maintenance, improvement or alteration of any deck or other raised platform within the curtilage of a dwellinghouse for any purpose incidental to the enjoyment of that dwellinghouse. Class 3E: The erection, construction, maintenance, improvement or alteration of any gate, fence, wall or other means of enclosure any part of which would be within or would bound the curtilage of a dwellinghouse. PART 2: SUNDRY MINOR OPERATIONS Class 8: Formation of means of access to an unclassified road. Class 9: Stone cleaning or painting of the exterior of a building. No such development shall be carried out at any time within this Part and these Classes without the express grant of planning permission. Reason: To protect the sensitive area and the setting of the proposed dwellinghouses, in the interest of visual amenity and public health, from unsympathetic siting and design of developments normally carried out without planning permission; these normally being permitted under Article 2(4) of the Town and Country Planning (General Permitted Development) (Scotland) Order 1992 (as amended). 18. PP – Provision of Play/ Amenity Space No development shall commence until details for the provision and maintenance of areas of communal open space and equipped play area(s) relating to the development been submitted to and approved in writing by the Planning Authority. The details shall comprise EITHER: Direct Provision of Play/Amenity Space: i) Provision to satisfy the minimum standards set out in the Development Plan; 6sqm of equipped play space and 12sqm of informal open space per dwelling unit; ii) Specification of play equipment to be installed, including surface treatments and any means of enclosure, designed in accordance with the provisions of BS5696 (Play Equipment Intended for Permanent Installation Outdoors); iii) Proposals for the timing of the implementation of the play area(s) in relation to the phasing of the development; iv) A maintenance schedule for communal open spaces and equipped play areas in accordance with the provisions of BS5696 including details of on- going inspection, recording and procedures for detailing with defects. Page 35
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The communal open space and equipped play area(s) shall be provided in accordance with the duly approved details and shall be retained and maintained to the specified standards thereafter. OR: Indirect Provision of Play/Amenity Space: The provision of a direct financial contribution to be held and administered by the Council for the purpose of providing for the delivery of a commensurate play/amenity space to serve the development within a later phase of the development of designations H3029. The calculation of the value of the direct financial contribution will be based upon the cost of delivery and ongoing maintenance of a facility which would meet the Council’s minimum playspace requirements for the approved development as set out in the Argyll and Bute Local Development Plan 2. The development hereby approved shall not be first occupied until such time as a formal agreement between the developer and the Council for the payment and administration of the direct financial contribution for the deferred provision of playspace has been signed. Reason: In order to secure provision of communal open space and equipped play areas within the development in accordance with the minimum standards set out in the Development Plan. Note for the Applicant/Developer: It is noted that discharge of this condition by means of ‘direct provision of play/amenity space’ would require to be the subject of a further application for planning permission given that the development as approved does not include sufficient site area to accommodate the requisite play/amenity space. It is further advised that discharge of this condition by means of ‘indirect provision of play/amenity space’ shall require to be the subject of an appropriate formal agreement between the Developer and the Council under the provisions of either S75 of the Town and Country Planning (Scotland) Act 1997, or the provisions of S69 of the Local Government (Scotland) Act 1973. ADDITIONAL NOTES TO APPLICANT • A Road Opening Permit under the Roads (Scotland) Act 1984 must be obtained from the Council’s Roads Engineers prior to the formation/ alteration of a junction with the public road. • The access shall be constructed and drained to ensure that no surface water is discharged onto the public road. • The Applicant is advised to contact Scottish Water completing and submitting a Pre- Development Enquiry (PDE) Form directly to Scottish Water via their Customer Portal prior to any formal Technical Application being submitted. Transport Scotland Informatives • The Applicant should be informed that the granting of planning consent does not carry with it the right to carry out works within the trunk road boundary and that permission must be granted by Transport Scotland’s Roads Directorate. Where any works are required on the trunk road, contact details are provided on Page 36
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Transport Scotland’s response to the Planning Authority which is available on the Council’s planning portal. • Trunk Road modification works shall, in all respects, comply with the Design Manual for Roads and Bridges and the specification for Highway Works published by HMSO. The developer shall issue a certificate to that effect signed by the design organisation. • Trunk Road modifications shall, in all respects, be designed and constructed to arrangements that comply with the Disability Discrimination Act; Good Practice Guide for Roads published by Transport Scotland. The developer shall provide written confirmation of this, signed by the design organisation. • The road works which are required due to the above Conditions will require a Road Safety Audit as specified by the Design Manual for Roads and Bridges. • Any trunk road works will necessitate a Minute of Agreement with the Trunk Roads Authority prior to commencement. Page 37
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 COMMITTEE REPORT APPENDIX A – RELATIVE TO APPLICATION NUMBER: 22/00680/PP PLANNING LAND USE AND POLICY ASSESSMENT 1. Introduction 1.1. The proposal, the subject of this application, is seeking to secure planning permission for the erection of 8 detached dwellinghouses, the formation of vehicular access and associated servicing infrastructure. 1.2. The key planning considerations in this case are: a) Compliance with the Development Plan and other relevant planning policy; and b) Any other material considerations. 2. Settlement Strategy 2.1. The application site covers an area of approximately 0.94ha which is currently agricultural land. Policy 9 of NPF4 confirms under criterion (b) that proposals on greenfield sites will not be supported unless the site has been allocated for development, or the proposal is explicitly supported by policies in the Local Development Plan [LDP2]. This is further established by Policy 16 of NPF4 which supports the development of new homes on allocated sites within LDPs. 2.2. A key role of LDP2 is to provide an effective land supply for new development. This provision is primarily set out in the form of allocations for different specified uses. The allocations include an indication of the number of homes that may be accommodated on housing sites. It is noted that the housing provision numbers are indicative, and in appropriate circumstances may be varied at the discretion of the Planning Authority. 2.3. In terms of the Local Development Plan Settlement Strategy, the application site lies within a defined settlement and utilises part of an allocated housing site under reference: H3029 within LDP2 which has an indicative capacity of 26 units and is within the settlement of Lochgair. The allocation within LDP2 was included to provide an opportunity to meet an identified need for housing, including affordable housing. Housing allocations are specifically intended to address the housing requirements identified in the Local Housing Strategy, informed by the Housing Need and Demand Assessments supplemented by local housing studies. The allocation of this site within LDP2 therefore demonstrates a housing need for the area in accordance with LDP2 Policy 64. 2.4. Drawing the above together, residential development at the site is considered acceptable in principle, subject to the acceptability of the detailed matters set out below. 3. Location, Nature and Design of Proposed Development 3.1. Lochgair is classed as a Village/Minor Settlement which has developable land, is on a trunk road, a hotel and a village hall but no shop or primary school. The scale and nature of this single allocation for housing is considered to be commensurate to the village capacity and appropriate to provide for growth into the future. H3029 allocation contributes to the established housing land supply in this area. The allocation carries a requirement for a minimum of 25% affordable housing delivery. Page 38
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 3.2. NPF4 Policy 15(a) seeks development proposals to contribute to local living including, where relevant, 20-minute neighbourhoods. To establish this, consideration will be given to existing settlement pattern, and the level and quality of interconnectivity of the proposed development with the surrounding area, including local access to a number of facilities. 3.3. The LDP2 settlement strategy seeks to deliver sustainable levels of growth by steering the majority of development to our existing settlements where the most of our current infrastructure, services, employment opportunities, housing and community facilities are to be found and thereby making best use of these resources is a sustainable approach to development. In this instance, the site, by virtue of being allocated as a housing allocation site, would reasonably comply with NPF4 Policy 15 given the scale of the environment within which the development is to be located, and given its compliance with the existing settlement pattern and the level and quality of interconnectivity of the proposed development with the surrounding area where people can reasonably meet the majority of their daily needs within a reasonable distance of their home. 3.4. This application is for the development of eight newbuild dwellings with vehicular access and associated infrastructure and landscaping. The site is located on the southern outskirts of Lochgair, immediately west of the A83 and is surrounded by rough open land to the south and east with forested land and residential dwellings to the north and west. The proposal will form the new southern extent of Lochgair. It is positioned between the built-up area of the rural settlement to the north and the open countryside to the south. By virtue of its inclusion within LDP2 as a housing allocation, it has already been accepted that this is a suitable site for housing in landscape terms and subject to an acceptable layout and good landscaping (to be controlled by planning condition), the proposal would accord with Policies 01 and 04 of LDP2 and Policy 9 of NPF4. 4. Affordable Housing 4.1. Policy 16 of NPF4, and Policy 67 of the LDP2 require all new housing developments of 8 or more units to contribute a proportion of affordable housing, with a benchmark minimum contribution of 25% of the total number of units on the site. In addition, all new developments of this scale will be required to provide a range of house types and sizes to meet the local housing needs and demand identified in the HNDA for each housing market area. 4.2. In this case, the proposal looks to develop eight 3–4-bedroom dwellings as part of a wider allocation site. The proposed site plan shows an indicative future layout which includes the affordable housing requirement for the allocation. It is common practice for housing developers to build larger sites in phases to allow the initial development to release funds to construct the remainder of the site. To ensure that the 25% affordable housing is delivered, a planning condition is required which would require the Applicant to pay a commuted sum towards affordable housing should the future phase of development not be forthcoming. Subject to the inclusion of the planning condition, the proposal would accord with NPF4 Policy 16 and LDP2 Policy 67. 5. Road Network, Parking and Associated Transport Matters 5.1. The site is proposed to be accessed from a new, single priority junction to be located on the eastern site boundary adjoining the A83 trunk road. The internal access layout is formed in a ‘T’ shape from the junction, with indicative links to future site phases connecting into the internal road layout to the north and south. Pedestrian footways are proposed on both sides of the carriageway with an indicative pedestrian link annotated outwith the development site boundary linking the proposed site to the village centre by Page 39
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 the existing Upper Lochgair access road. The internal road layout is proposed to be constructed to an adoptable standard and each dwelling is served with its own offroad parking provision. The number of parking spaces proposed accords with the Local Development Plan’s Parking Standards. 5.2. NPF4 Policy 13 seeks to encourage, promote and facilitate developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduce the need to travel unsustainably. The development is not considered to be a significant travel generating use or a proposal where it is considered important to monitor travel patterns resulting from the development. Significant public representation has been received raising concerns regarding road safety arising from the development. 5.3. The Council’s Area Roads Officer provides commentary on the internal road layout of the site and has no objections to the scheme subject to the inclusion of a number of planning conditions relating to the proposal meeting Design Standards in relation to each dwelling connection access point onto the adoptable road layout; car parking numbers to serve each dwelling; no vehicular connection to the UC66 Upper Lochgair Road and the provision of a pedestrian footway link between the development and the UC66 Upper Lochgair road. Planning conditions are therefore required in accordance with this recommendation. It is noted that the pedestrian footway link lies on land outwith the development boundary of this planning application, but within land which the Applicant has control of. On this basis a planning condition requiring the prior granting of planning permission for a separate application covering the pedestrian link before any works commence on this development, should be attached to any subsequent decision notice. This is to ensure delivery of this link which provides key connectivity of the site to the village centre and public transport provision. 5.4. Transport Scotland have provided commentary on the acceptability of the site’s access junction with the A83 due to it being a connection to the trunk road. During the progression of the application, Transport Scotland have sought several amendments and further information requests with the Applicant due to the lack of information to allow them to fully assess the proposal’s compliance with the Design Standards for priority junctions as set out in the Design Manual for Roads and Bridges. The Applicant has subsequently provided revised and additional information including a Speed Survey to meet Transport Scotland’s information requirements providing clarification on: a) The purpose of the proposed rural hardstanding areas and A83 crossing at the junction; b) The submission of a speed survey to demonstrate that a lower Stopping Sight Distance (SSD) is appropriate; c) If any consideration has been given to locating the proposed access within the 40mph speed limit at the location of the existing gated access; d) Submission of a Departures from Standards application to Transport Scotland due to the proposed 0.26m object height of visibility not being achievable to the south of the proposed access; and e) that the proposed ‘temporary pedestrian access’ link is of an appropriate standard to ensure its use should future phases not come forward as there are no pedestrian footway facilities on the A83. 5.5. It is also confirmed that Transport Scotland would not welcome the extension of the 40mph limit to a location beyond the development site. 5.6. Transport Scotland confirm they remove their holding objection subject to the inclusion of planning conditions for the prior agreement of the access construction method and type, provision of the pedestrian access link prior to occupation and that no drainage Page 40
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 connections to the trunk road drainage system shall occur. Transport Scotland also confirm that development of this first phase would not preclude the delivery of the wider housing allocation site and the design of the proposed junction is appropriate for the level of housing of the allocation. 5.7. Sufficient information has now been submitted in support of the application which demonstrates to the satisfaction of the key statutory consultees, Transport Scotland and the Council’s Area Roads Officer that the proposal would not adversely impact road safety. On this basis, the proposal accords with NPF4 Policy 13 and LDP2 Policies 01, 35 and 38. 6. Built Environment 6.1. Policy 14 of NPF4, promotes well designed developments that make successful places by taking a design-led approach and applying the Place Principle. Proposals should be consistent with the six qualities of successful places: healthy, pleasant, connected, distinctive, sustainable, and adaptable. Policies 5 and 10 of LDP2 relate to design and place making and development setting, layout and design. 6.2. Policy 16(c) of NPF4 requires housing mixes of schemes to improve affordability and choice by being adaptable to changing and diverse needs. The development provides an initial housing mix of 3-4-bedroom, detached units. 6.3. The design considers the relationship between the buildings to each other and to the street, and all streets are overlooked to create pleasant pedestrian environments and active street frontages. Car parking is contained on-plot to promote a pedestrian friendly environment throughout the development. 6.4. In respect of the character and density of surrounding development, the wider area predominantly takes a linear form to roads with a higher density of units erected within Upper Lochgair, formed of a mix of housing types and heights. 6.5. The housing development takes form centrally within the site with a vegetated buffer to be provided along the eastern site boundary, and indicative future development layouts being shown to the north and south of the proposal. The architecture of the site takes form from modern vernacular comprising simple forms of 1 ½ storey structures with a limited material palette of rendered elevations, grey UPVC fenestration and tiled roofs. The scale and massing reflect that found within the wider settlement area. All units are proposed with traditional features of dual pitched roofs. The design, scale and massing of the housing is appropriate for its setting. The layout of the housing provides a central street network with adequate permeability being provided through the inclusion of a pedestrian link to Upper Lochgair Road which would be subject to a separate planning application and conditioned through this decision. All residential units would have private amenity space, and the plot ratios are considered to be acceptable. 6.6. The development has been designed and will be constructed to make provision for the access of people with disabilities including the design of dwellings to enable the internal layout to be readily adaptable for use by disabled persons. 6.7. NPF4 Policy 11(a) states that development proposals for all forms of renewable, low- carbon and zero emissions technologies will be supported. The proposed development, through the provision of air source heat pumps to serve each dwellinghouse, would contribute to the expansion of low-carbon and zero emission technologies. Page 41
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 6.8. Policy 68 of LDP2 require residential developments at the scale of the proposed allocation to provide associated housing green space of both a casual and formal nature. This comprises a minimum of 12sqm of communal casual open space per dwelling, and 6sqm of children’s play space, including provision for under 5 year olds. This policy also requires the developer to maintain and provide public liability insurance for the play space. This application is for the first phase of development for the allocation. The scheme as put forward looks to construct 8 dwellings with the remaining dwellings and the associated housing greenspace brought forward within the later development phases. To accord with policy requirements and ensure the delivery of the open space and play space for the allocated site as a whole, a planning condition is required to agree either the direct provision of this through a separate planning application or the indirect provision through an appropriate formal agreement and commuted sum. Subject to this condition, the proposal accords with LDP2 Policy 6 and 68 and NPF4 Policy 20 which support the provision of enhanced blue and green infrastructure and requires the provision of well- designed play, recreation and relaxation areas. 6.9. The overall development is considered to present an attractive and appropriate residential design for this site which will accord with policy objectives of the LDP and NPF4. The proposals are therefore considered to accord with the requirements of policies 5, 8, 9, and 10 LDP2 and Policies 14, 16 and 17 of NPF4. 7. Natural Environment 7.1. Policy 1 of NPF4 requires that significant weight is given to the global climate and nature crisis when consideration is given to new development. Policy 3 seeks to ensure that development will conserve, restore and enhance biodiversity. Policy 4 seeks to protect, restore and enhance natural assets including protected areas. 7.2. The development proposed by the current planning application is considered appropriate in terms of its type, location and scale such that it will have no unacceptable impact on the natural environment. The proposed development is not within any designated European site of natural environment conservation or protection, it is not located within a National Park, a National Scenic Area a SSSI or RAMSAR site, or a National Nature Reserve. Neither is it located within a site designated as a local nature conservation site or within an area identified as wild land. Whilst the site is located within the West Loch Fyne (Coast) Local Landscape Area, the application proposes a small scale residential development, within an area identified for housing development in LDP2, where it will be viewed in the context of the existing built environment of Lochgair, therefore it is the considered opinion of the Planning Authority that the proposal will not result in any significant adverse effects on the integrity of the area or the qualities for which it has been identified. 7.3. With regards to the need in NPF4 Policy 3 to secure biodiversity improvements, it is not considered that there are any issues of compliance with Policy 3. Whilst the Supporting Statement details that habitat improvements have been incorporated into the site design including the provision of native species planting within the SUDS features, it is considered appropriate to impose a condition on the grant of any permission to secure the finer detail of these proposals as part of the wider landscaping and boundary treatment measures for the site. With a condition to secure the finer details of the biodiversity enhancement, the proposal aligns with the broad aims of NPF4 Policy 3 and is consistent with the requirements of LDP2 Policy 73. 8. Impact on Soils and Contaminated Land Considerations Page 42
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 8.1. The site comprises a field of improved grassland which is categorised as Class 5 (No peatland habitat recorded). The development of this site would therefore not adversely impact prime agricultural land in accordance with LPD2 Policy 83, nor high quality peatland habitat. In accordance with NPF4 Policy 5 and LDP2 Policy 79, a planning condition would be required to secure a soil management plan during the construction phase of the development. 8.2. In accordance with LDP2 Policy 82, the Council’s Contaminated Land Officer requires the inclusion of a planning condition for the agreement and implementation of a contaminated land site investigation assessment due to the proposal being the redevelopment of land where there is an indication of a previous use which may have been contaminative. 9. Historic Environment 9.1. Policy 7 of NPF4 requires developments to demonstrate how they have mitigated against potential impacts on the historic environment. Policy 15 of LDP2 further iterates that development proposals will not be acceptable where they fail to protect, preserve, conserve or enhance the established character of the historic built environment. Policy 21 of LDP2 seeks to ensure the same protection occurs with archaeological heritage. 9.2. There are no designated heritage assets within the Proposed Development Area or within the immediate wider area to which the proposal would affect the setting of. With regards to non-designated heritage assets, it is understood that the application site lies in a landscape populated with recorded archaeological sites of prehistoric, medieval and later date. The large area of ground that will be disturbed by this development stands a good chance of unearthing visible or buried unrecorded remains which could be of any period and as such the West of Scotland Archaeological Service recommend the inclusion of a programme of archaeological works as a planning condition on any subsequent decision. 9.3. Having due regard to the above and subject to the condition recommended by the West of Scotland Archaeology Service, it is concluded that the proposal would not have any adverse impacts on the historic environment, including listed buildings and their settings, and is therefore consistent with the provisions of Policy 7 of NPF4 and Policies 15 and 21 of LDP2. 10. Infrastructure and Waste Management 10.1. Policy 2 of NPF4 requires that development is sited and designed to adapt to current and future risks from climate change. The site is not at risk of fluvial flooding. The indicative limits of surface water flooding shown upon the SEPA Flood Map overlies with part of the north and middle sections of the site. These areas are where two small watercourses cross through the site. The indicative limits, however, are not overlain with the locations of the proposed newbuilds but do come near Plot 1. The submitted Flood Risk Assessment confirms that all the proposed dwellings are outside of the modelled flood extent from the small watercourse and the dwellings are outwith the surface water flood extent from the drains to the south. The Flood Risk Advisors recommend that Finished Floor Levels are at leas 0.3m above surrounding ground level as a mitigation measures, given the proximity to the modelled surface water flood extents. The Advisor also recommends a planning condition to ensure the post development runoff rate arising from the swale is attenuated to the greenfield runoff rate before discharge from the site. Subject to the inclusion of the planning conditions the proposal accords with NPF4 Policy 22 and LDP2 Policy 55. Page 43
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 10.2. The proposal will be connected to the mains water supply and mains foul drainage infrastructure within the area subject to formal capacity reviews post planning consent with Scottish Water. The infrastructure connections are therefore considered acceptable. 10.3. NPF4 Policy 12 seeks to encourage, promote and facilitate development that is consistent with the waste hierarchy as defined within the policy document. The development the subject of this planning application seeks to secure permission for 8 dwellinghouses. Whilst this is a development likely to generate waste when operational, it will be served by regular waste uplifts by the Council and will be expected to comply with the Council’s adopted and enforced recycling and reuse strategy. The application shows an area within the grounds of each dwellinghouse for the storage of refuse bins. A planning condition is required to agree uplift locations by the Council’s Refuse Collection Vehicle within the site. Subject to the inclusion of this condition, the proposal would accord with NPF4 Policy 12 and LDP2 Policy 63. 11. Impact on Amenity 11.1. Policy 14 of NPF4 does not support developments that would be detrimental to the amenity of the surrounding area. Policy 8 of LDP2 requires inter alia that developments should be site to avoid overshadowing or overlooking. 11.2. The Council’s Environmental Health Officer highlights the potential noise impacts that could arise through the construction of the development. Construction inevitably results in disturbance, vibration, noise, and dust which can adversely impact upon the amenity of nearby residents. It is therefore recommended that construction hours are restricted by planning condition to protect the amenity of the area in terms of a noise nuisance. A planning condition is also required to restrict the operating noise level of the proposed air source heat pumps to be installed. 11.3. The proposal is sited with good distances from neighbouring residential dwellings and therefore the proposal does not give rise to any impacts on neighbouring amenity by way of overlooking, overshadowing, loss of light or privacy. The proposed use is accepted as being compatible with the surrounding land uses by way of its inclusion as an allocation within the LDP2. The internal housing arrangement of the scheme has been designed to ensure that the amenity of the new occupants will not be adversely affected. 11.4. On this basis, the proposal is considered to comply with Policy 14 of NPF4 and Policy 8 of LDP2. Page 44
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 COMMITTEE REPORT APPENDIX B – RELATIVE TO APPLICATION NUMBER: 22/00680/PP LIST OF CONTRIBUTORS Contributor Name Contributor Address Date response received 1 Miss Kirsty Morrison Ard Na Dail Upper Lochgair Lochgair Lochgilphead Argyll And Bute 23.05.2022 2 Mr Michael Reid Westhome Gallanach Lochgair Lochgilphead Argyll And Bute 29.05.2022 3 Bill Connor No Address Provided 31.05.2022 4 Michael Cuthbert Knock Steading Upper Lochgair Lochgair Lochgilphead 26.05.2022 5 Marion Quinn An Airigh Upper Lochgair Lochgair Lochgilphead 27.05.2022 6 Allan Redpath Knock Farmhouse Upper Lochgair Lochgair Lochgilphead 26.05.2022 7 Mr Gordon Merrilees Ionad Socair Upper Lochgair Lochgair Lochgilphead 26.05.2022 8 Beverly Cuthbert Knock Steading Upper Lochgair Lochgair Lochgilphead 27.05.2022 9 Margaret Gray Bruachan Lochgair Lochgilphead Argyll And Bute 27.05.2022 10 David Dunlop Birkhill Lochgair PA31 8SD 27.05.2022 11 Mrs Anna Watkiss Orran Upper Lochgair Lochgair Lochgilphead Argyll And Bute 31.05.2022 12 H Rogan Lochgair 26.05.2022 13 Will Rudd Melford Cottage Lochgair 26.05.2022 14 Margaret Rudd Melford Cottage Lochgair 26.05.2022 15 Dee Carrick 4 Upper Lochgair Lochgair Argyll And Bute 26.05.2022 16 Yvonne Oldfieldnt 1 Gallanach Lochgair Lochgilphead Argyll 26.05.2022 17 Mr Douglas Murray Redhouses Lochgair Lochgilphead Argyll And Bute 26.05.2022 18 Wanda Dunlop Birkhill Lochgair PA31 8SD 27.05.2022 19 Greg Neeson An-Airigh Lochgair 27.05.2022 20 Alison Wilkinson No Address Provided. 27.05.2022 21 David Wilkinson Cowal View Lochgair PA31 8SB 27.05.2022 22 Mrs Susan Grocock Bruadair Inverliever Ford Lochgilphead Argyll And Bute 29.05.2022 23 Ms Isabel Brodie 10 Gryffe Castle Kilmacolm Road Bridge of Weir PA11 3PU 30.05.2022 24 P Gush 1, Gallanach, Lochgair, Lochgilphead, Argyll 30.05.2022 25 Janice Williams Marden Lochgair PA31 8SD 30.05.2022 26 Carol Braidwood 2 Upper Lochgair Lochgair PA31 8SB 30.05.2022 27 Ken Hayes No Address Provided 30.05.2022 Page 45
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 28 Mrs Victoria Fraser Asknish House Lochgair Lochgilphead Argyll And Bute 30.05.2022 29 Sandra Richardson The Sheiling Lochgair Lochgilphead Argyll And Bute 31.05.2022 30 Mr Brian Johnstone Fascadale Lochgair Lochgilphead Argyll And Bute 18.05.2022 31 Marion Lacey Westcroft Lochgair Lochgilphead Argyll And Bute 25.05.2022 32 Robert Lacey Westcroft Lochgair Lochgilphead Argyll And Bute 25.05.2022 33 Mr Fred Bruce Waterford Lochgair Lochgilphead Argyll And Bute 30.05.2022 34 Karen Connor No Address Provided 30.05.2022 35 Barbara Service No Address Provided 30.05.2022 36 Alex Carrick 4 Upper Lochgair Lochgair Argyll And Bute 27.05.2022 37 Jean C Smith 6 Gallanach Lochgair PA31 8SD 27.05.2022 38 Cllr Dougie Philand Argyll First 32 Fernoch Crescent Lochgilphead Argyll 28.06.2022 39 Barabel Mckay 1 Ardcastle View Lochgair PA31 8UJ 30.05.2022 40 Tom Mckay 1 Ardcastle View Lochgair PA31 8UJ 30.05.2022 41 Michael Cuthbert Knock Steading, Lochgair PA31 8SB 30.05.2022 Page 46
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 APPENDIX C: EIA SCREENING REPORT TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) (SCOTLAND) REGULATIONS 2017 SCREENING OPINION OF ARGYLL AND BUTE COUNCIL 22/00680/PP | ERECTION OF 8 DWELLINGHOUSES AND FORMATION OF VEHICULAR ACCESS | LAND EAST OF KNOCK FARMHOUSE, UPPER LOCHGAIR, ARGYLL AND BUTE Under the provisions of Regulation 11 of the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017, Argyll and Bute Council as Planning Authority must adopt a screening opinion where an application before them is a Schedule 2 application of the Regulations. Development falling within Schedule 1 of the Regulations will always be EIA development for which an EIAR is required to accompany an application for development consent. The development proposed in this case is Schedule 2 development by virtue of being identified in Schedule 2, 10(b) which has a 0.5ha site area threshold and relates to “urban development projects, including the construction of shopping centres and car parks, sport stadiums, leisure centres and multiplex cinemas”. Development falling within Schedule 2 (as in this case) may be EIA development if the development proposed is assessed to be ‘likely to have significant effects on the environment by virtue of factors such as its nature, size or location’. In making such a decision, regard shall be had to the ‘selection criteria’ set out in Schedule 3, namely the characteristics of the development, the location of the development and the characteristics of the potential impact. 1. Characteristics of development The characteristics of development must be considered having regard, in particular, to— a) the size and design of the development; b) cumulation with other existing development and/or approved development; c) the use of natural resources, in particular land, soil, water and biodiversity; d) the production of waste; e) pollution and nuisances; f) the risk of major accidents and/or disasters which are relevant to the project concerned, including those caused by climate change, in accordance with scientific knowledge; g) the risks to human health (for example due to water contamination or air pollution). In respect of the above it is considered that the following evaluation is appropriate: The proposal will have potential environmental consequences in terms of building activity and potential noise disturbance to the local community during the construction phase of the development. However, these are normally associated consequences of new residential development, and if properly managed in respect of appropriate controls on working hours, noise limits and traffic management through the use of planning conditions, such matters should not give rise to significant environmental consequences which would require the production of an EIA. In respect of waste, a waste management plan and conditions in respect of the management of waste during and post construction is considered to be an appropriate approach and no waste products which would require specific treatment and known to exist on the site. Page 47
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 The site is accessible by a range of transport modes. There are public bus links within Lochgair. Any pedestrian connectivity to the village can be considered as part of the planning application. No complex or significant issues in respect of 1(a-g) which suggest an EIA is required. No significant environmental issues are therefore considered to arise as a result of this proposal which are not considered to be capable of being addressed in sufficient detail within the context of a detailed planning application. 2. Location of development The environmental sensitivity of geographical areas likely to be affected by development must be considered having regard, in particular, to— a) the existing and approved land use; b) the relative abundance, availability, quality and regenerative capacity of natural resources (including soil, land, water and biodiversity) in the area and its underground; c) the absorption capacity of the natural environment, paying particular attention to the following areas— a. wetlands, riparian areas, river mouths; b. coastal zones and the marine environment; c. mountain and forest areas; d. nature reserves and parks; e. European sites and other areas classified or protected under national legislation; f. areas in which there has already been a failure to meet the environmental quality standards, laid down in Union legislation and relevant to the project, or in which it is considered that there is such a failure; g. densely populated areas; h. landscapes and sites of historical, cultural or archaeological significance. In respect of the above it is considered that the following evaluation is appropriate: The development, in terms of scale and location, accords with the adopted Local Development Plan 2 (2024) land use allocation policy 01 and the site is located within an identified settlement area. The site forms part of housing allocation site H3029 and is within the suggested housing units figure. The site is not located within a designated site, nor would it impact on any landscape or sites of historical, cultural or architectural significance. The site relates to agricultural land which does not form prime agricultural land and does not include high quality peatland habitat. The site itself is an agricultural site that currently is utilised for grazing and has little complex biodiversity or ecological value. The application includes a considered landscaping scheme to encourage biodiversity enhancement of the site. The imposition of planning conditions can ensure that the biodiversity enhancement is suitable for the site. There are no identified sensitive designated areas likely to be adversely impacted by the proposal. Any impacts associated with its construction and operation are considered to be capable of evaluation/resolution through the normal planning process. It is not considered that the proposal will have any likely significant effects on landscapes or sites of historical, cultural or archaeological significance as none are identified either on or Page 48
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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 adjacent to the site and the proper design and landscaping of the proposal will ensure that an acceptable landscape “fit” is achieved through the normal process of a planning application. No complex or significant environmental issues in respect of 2 (a), (b) and (c) (i-viii) are considered to arise as a result of this proposal. All identified and relevant matters are considered to be capable of being addressed in sufficient detail the context of a detailed planning application. 3. Characteristics of the potential impact The likely significant effects of the development on the environment must be considered in relation to criteria set out in paragraphs 1 and 2 above, with regard to the impact of the development on the factors specified in regulation 4(3), taking into account— a) the magnitude and spatial extent of the impact (for example geographical area and size of the population likely to be affected); b) the nature of the impact; c) the transboundary nature of the impact; d) the intensity and complexity of the impact; e) the probability of the impact; f) the expected onset, duration, frequency and reversibility of the impact; g) the cumulation of the impact with the impact of other existing and/or approved development; h) the possibility of effectively reducing the impact. The potential impacts of the proposal on the site and surrounding area have to be assessed by Officers in terms of the extent, trans-boundary nature, magnitude and complexity, probability and duration, frequency and reversibility. The impact of the development is likely to be localised and would not have a wider environmental impact beyond the site. There is little potential for a trans-boundary impact or impacts with magnitude and complexity. There are no impacts to be considered in terms of probability and duration, frequency and reversibility. Overall, it is not considered that the characteristics of the potential impact are likely to have a likely significant long-term effect upon the local or wider environment. There will undoubtedly be impact on existing residents associated with noise and disturbance connected construction of the proposed houses. However, through the requirement of appropriate controls in respect of hours of working it is considered that such impacts as arise can be appropriately managed and controlled through the planning application process. No complex or significant EIA issues in respect of 3(a-h) are considered to arise as a result of this which are not considered to be capable of being addressed in sufficient detail within the context of a detailed planning application outside of the EIA assessment process. Conclusion Accordingly, for the reasons set out above, and under the powers conferred by Regulation 6 of the Environmental Impact (Scotland) Regulations 2017, Argyll and Bute Council confirms that the development, although falling within Schedule 2 Part 10(b) is not of a type or nature to require the submission of an Environmental Impact Assessment. Laura MacDonald Planning Officer On behalf of Argyll and Bute Council 13/01/2025 Page 49
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" " © Crown Copyright and database right 2024 All rights reserved. OS license (customer) account number AC0000849384 Location Plan Relative to: 22/00680/PP O 1:2,500 0 20 4010 Meters Application Site Page 51
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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 53 Agenda Item 5
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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 54
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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 55
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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 56
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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 57
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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 58
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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 59
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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 60
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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 61
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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 62
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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 63
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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 64
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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 65
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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 66
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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 67
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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 68
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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 69
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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 70
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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 71
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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 72
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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 73
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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 74
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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 75
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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 76
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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 77
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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 78
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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 79
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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 80
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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 81
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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 82
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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 83
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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 84
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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 85
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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 86
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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 87
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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 88
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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 89
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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 90
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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 91
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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 92
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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 93
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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 95 Agenda Item 6
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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 96
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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 97
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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 98
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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 99
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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 100
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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 101
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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 102
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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 103
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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 104
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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 105
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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 106
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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 107
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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 108
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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 109
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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 110
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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 111
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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 112
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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 113
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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 114
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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 115
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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 116
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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 117
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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 118
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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 119
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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 120
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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 121
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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 122
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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 123
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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 124
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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 125
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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 126
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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 127
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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 128
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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 129
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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 130
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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 131
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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 132
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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 133
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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 134
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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 135
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1 ARGYLL AND BUTE COUNCIL Planning, Protective Services and Licensing Committee DEVELOPMENT AND INFRASTRUCTURE 17 December 2025 JOINT PUBLIC HEALTH PROTECTION PLAN 2025-2027 1.0 EXECUTIVE SUMMARY 1.1 Purpose: This report invites Members to approve the Joint Public Health Protection Plan 2025-2027 which outlines our health protection priorities for the period and reviews the previous plan. This is a statutory plan, required under the Public Health etc. (Scotland) Act 2008, has been developed in conjunction with Argyll and Bute Council, Highland Council and NHS Highland. It is also consistent with the Councils corporate priorities. 1.2 The Public Health etc. (Scotland) Act 2008 outlines a range of statutory powers for the purposes of health protection in a situation when action needs to be taken to protect public health, sometimes against the expressed wishes of an individual or organisation. Under the Act, health boards assume the lead role for health protection activities relating to people, and local authorities retain the lead role for premises and property. The plan strengthens the partnership approach between the three agencies and ensures that appropriate “health protection arrangements” are in place between the Council’s environmental health service and the Consultant in Public Health Medicine, NHS Highland, 1.3 The plan was approved by Highland Council at their Communities and Place Committee on the 6 November 2025 and is to be considered by NHS Highland Board in early course. 1.4 Financial: The work will be undertaken principally by the Council’s environmental health service with support from other areas of Regulatory Services. The plan has been developed having regard to available resources and budget. As reported previously to Committee, the resources available to Environmental Health have to be prioritised, focusing on areas of greater public health significance. Where statutory responsibilities require a higher level of service standard, the team are continually exploring ways of delivering services more efficiently. . 1.5 Recommendations Members are invited to: - (i) Approve the Joint Public Health Protection Plan for 2025-2027 (Appendix I), recognising the key role of local authorities and environmental health (ii) Formally reaffirm the appointments of the Regulatory Services and Building Standards Manager, as the Council’s Designated Competent Person under the Public Health etc. (Scotland) Act 2008, and the appointments of Depute Designated Competent Persons as detailed in section 4.8 of this report and 4.2 of the JHPP. (iii) Agree that the Regulatory Services and Building Standards Manager signs the JHPP plan on behalf of the Council and takes the necessary steps to deliver the plan. Page 137 Agenda Item 7
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2 ARGYLL AND BUTE COUNCIL Planning, Protective Services and Licensing Committee DEVELOPMENT AND INFRASTRUCTURE 17 December 2025 JOINT PUBLIC HEALTH PROTECTION PLAN 2025-2027 2.0 INTRODUCTION 2.1 Local authorities have a significant role to play in public health and health protection. The Public Health etc. (Scotland) Act 2008 place a requirement on NHS Boards to prepare, in conjunction with local authorities, a Joint Public Health Protection Plan (hereafter referred to as JHPP) every 2 years. The plan requires to be formerly approved by each agency and outline the health protection priorities for the forthcoming period of the plan. 2.2 The Joint Health Protection Plan (JHPP) is prepared to ensure the requirements of the Public Health etc. (Scotland) Act 2008 is carried out by Health Boards and local authorities. Guidance on preparing the plan requires it to cover working arrangements and priorities for the protection of public health. The Plan is developed in conjunction with Argyll and Bute Council, Highland Council and NHS Highland. 3.0 RECOMMENDATIONS Members are invited to: - (i) Approve the Joint Public Health Protection Plan for 2025-2027 (Appendix I), recognising the key role of local authorities and environmental health (ii) Formally reaffirm the appointments of the Regulatory Services and Building Standards Manager, as the Council’s Designated Competent Person under the Public Health etc. (Scotland) Act 2008, and the appointments of Depute Designated Competent Persons as detailed in section 4.8 of this report and 4.2 of the JHPP. (iii) Agree that the Regulatory Services and Building Standards Manager signs the JHPP plan on behalf of the Council and takes the necessary steps to deliver the plan. 4.0 JOINT PUBLIC HEALTH PROTECTION PLAN 2025-2027 4.1 There is an expectation by the public that the NHS and Local Authorities undertake work which keeps people and communities safe and have adequate arrangements in place to deal with any incidents of disease which pose a risk to public health. This Plan details the extent of the health protection work which is being undertaken. It focuses our Health Protection activity and resources on key national and local priorities, provides a means to highlight our intentions and to report on our actions/progress. . Page 138
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3 4.2 Health Protection is the branch of public health which seeks to protect the public from being exposed to hazards which damage their health and to limit any impact on health when such exposures cannot be avoided. This includes the prevention, investigation and control of communicable diseases and environmental hazards. This work goes unnoticed, other than during a major outbreak or incident where the investigation and control of disease is paramount. Day-to-day work is undertaken principally by Environmental Health in the Local Authorities and colleagues within the Health Protection team in NHS Highland. The Plan seeks to ensure that the standards defined by statute, or expected by society are met, namely that food is safe to eat from commercial premises, that water is safe to drink, that air is safe to breathe, that workplaces and other facilities/attractions (e.g. leisure facilities etc.) are safe to use and that we have a good and healthy environment. Many of the areas covered by the plan match the statutory duties of the Environmental Health team. 4.3 The JHPP supports the existing close working relationships which exist between the three bodies and helps ensure that we are able to respond effectively to a public health incident or outbreak (e.g., E. coli 0157 outbreak, norovirus in the community, water and air quality issues). The plan also identifies national and local health protection priorities The Scottish Government and COSLA strategy ‘Public Health Priorities for Scotland’ emphasises the essential role of health protection work and workforce planning including environmental health is being taken forward at a national level. 4.4 The Plan, in Appendix I, is the sixth Highland JHPP, with the first plan being published in 2010 and targets resources at key national and local priorities and provides a number of key benefits: I ensures that there are effective arrangements in place between Councils and the NHS to deal with any incidents of disease or which pose a risk to public health. ii The Plan details the details the extent of the health protection works which is being undertaken on a proactive and preventative basis Iii focusses our activity and resources on key national and local priorities, provides a means to highlight our intentions and to report on our actions/progress. iv raises the profile of ‘health protection’ which largely goes unnoticed, other than during a major outbreak or incident where the investigation and control of disease is paramount. The day-to- day work is undertaken principally by environmental health to ensure that the standards are met. v provides confidence to elected members, and others, that appropriate arrangements are in place to respond to any suspected or confirmed outbreak or public health incident. 4.5 Section 1.2 of the plan provides background on health protection and trends on communicable disease. Sections 1.4 and 1.5 details the challenges of providing health protection over the areas given geography and the specific challenges to environmental health teams in workforce planning and prioritising existing resources on areas of greatest public health significance. Appendix II provides a useful infographic on the work of environmental health 4.6 The national and local priorities identified for the period are given in Table 2 on pages 17-23 of the plan. These have been developed by the three bodies to ensure key health protection priorities are addressed. As stated in the plan, the local priorities recognise the work undertaken by the environmental health teams in the following areas of responsibility and service delivery. Page 139
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4 (i) Protecting public health (ii) Preventing the spread of communicable diseases in the community • Improving standards of food safety (iii) Ensuring safe and potable drinking water supplies (iv) Improving standards of workplace health and safety standards (v) Promoting a safe environment and protecting the public from environmental hazards (vi) Providing safe private and short term let accommodation (vii) Ensuring adequate plans are in place to respond to incidents and emergencies 4.7 Section 3 of the plan (pages 24-42) provides an overview of the work undertaken by the partners over the period of the last plan, 2023-2025. The plan notes that progress has been made against almost all of the national and local priorities The established working arrangements, promoted through this plan, proved to be effective in responding to communicable disease outbreaks and general incident management (e.g., ad-hoc incidents including avian influenza, health advice relating to a pollution incident, blue-green algae and drinking water incidents). Some priorities have not been fully addressed due to new or emerging priorities or resourcing issues. These have been reviewed and where appropriate and relevant, are included in the 2025-27 JHPP. The programme to review joint procedures was not progressed, as planned, due to lack of available resources across all three agencies. On reflection, the lack of having an agreed timetable over the duration of the plan resulted in these reviews being delayed. 4.8 Actions have been identified in section 3.2 of the Plan (page 44), to improve delivery of the plan in the future: - (i) Provide a more structured timetable for the review of joint procedures. This provides a focus, supports resource deployment, and aids monitoring of the plan. It is proposed that all agencies meet on approval of the Plan, to implement this approach. (ii) To re-establish the multiagency agency Environmental Health Liaison Group. This will build relationships with other agencies, support learning and sharing best practice, and delivery of the JHPP. (iii) Regular meetings will be arranged to focus solely on delivering the Plan. This will review progress, revise priorities and consider emerging issues. 4.9 To meet national guidance, the plan concludes by providing information on the operational arrangements of the teams including specific health protection response plans, staff resources, details of designated staff under the Public Health Act, mutual aid arrangements, and out-of- hour arrangements. Argyll and Bute Council require to appoint a Competent Public Health Person, Deputes, and thereafter appointment of officers by the Local Authority Competent Person. This provides flexibility in authorising officers to meet specific circumstances, workload and demand, or new staff without having to amend the Plan or obtain Committee approval. It is recommended that the following appointments are made: Local Authority Designated Competent Person Alan Morrison, Regulatory Services and Building Standards Manager Depute Local Authority Designated Competent Person Mary Watt, Environmental Health Manager (East) Depute Local Authority Designated Competent Person Jacqui Middleton, Environmental Health Manager (West) Page 140
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5 Depute Local Authority Designated Competent Person Mark Parry, Principal Environmental Health Officer (Public Health) 4.10 There are significant pressures on environmental health services due to a national shortage of environmental health officers. These challenges are recognised by COSLA, and the Scottish Government and work is ongoing with the Royal Environmental Health Institute of Scotland (REHIS) and the Society of Chief Officers of Environmental Health in Scotland (SoCOEHS) to increase resilience of the service and a sustainable workforce. A new MSc Environmental health course at Abertay University commences in January 2026, and we have secured a place for our Trainee EHO. As a consequence, Argyll and Bute Council have been operating without 4 Environmental Health Officers and other posts for most of the last two years, despite repeated attempts to recruit and the development of new career pathways. Through our “grow our own” workforce strategy, we presently have a Trainee EHO, a Regulatory Services Officer undergoing a formal training pathway to become an EHO, and a Graduate Trainee Food Safety Officer. This reduces our operational capacity meantime, but is a medium term solution to develop Officers for the future. 5.0 CONCLUSIONS 5.1 Local authorities have a significant role to play in public health and health protection, and it is not solely for NHS services. Much of the work of local authorities is preventative and reduces the burden at primary care level. 5.2 The Joint Public Health Protection Plan for 2025-27 meets the Council’s statutory obligations under the Public Health (Scotland) Act 2008 5.3 The Plan was agreed by Highland Council on the 6 November 2025 and will be considered by NHS Highlands Board Following approval by all three agencies, the plan will be published to demonstrate the work being done to protect the health of the people who live, visit and work in the Highlands and Argyll & Bute. 6.0 IMPLICATIONS 6.1 Policy Consistent with Council priorities 6.2 Financial The plan will be delivered within our current service, although progress is dependent upon resource levels, other workload, and no reduction in resources 6.3 Legal Meets the Council’s legal obligations under Section 7 of the Public Health (Scotland) Act 2008. 6.4 HR None. 6.5 Customer Service No significant issues. 6.6 Risk: Delivery of the plan is dependent on resources and will be impacted by staff absence, vacancies, new service demands, service cuts, or significant reactive work. Priority will be given to delivering this plan, and the risks will be actively managed. In the event of an outbreak of incident, resources will be redirected from routine operational work 6.7 Climate Change Climate change actions are included within the plan. 6.8 Fairer Scotland Duty There are no implications. Page 141
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6 6.9 Equalities- protected characteristics No adverse impact 6.10 6.11 Consumer Duty Island communities Positive No impact 6.12 Children’s Rights and Wellbeing No impact Executive Director with responsibility for Regulatory Services Policy Lead Councillor: Gordon Blair For further information contact: Alan Morrison, Regulatory Services and Building Standards Manager, Tel: 01546 604292, email: alan.morrison@argyll-bute.gov.uk j/9027 Appendices Appendix I: Joint Health Protection Plan 2025-2027 Appendix II: Infogram illustrating the role of environmental health in public health Page 142
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Joint Health Protection Plan 25-27 v1.0 Page | 1 NHS Highland Joint Health Protection Plan (JHPP) 2025-2027 Prepared by Dr Jenny Wares, Mr Alan Morrison and Mr Alan Yates on behalf of NHS Highland, Argyll and Bute Council and Highland Council respectively September 2025 – December 2027 Issued 19/9/25 v1.0 Appendix I Page 143
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Joint Health Protection Plan 25-27 v1.0 Page | 2 Contents Introduction ..................................................................................................................... 3 1.1 The Joint Health Protection Plan ....................................................................... 4 1.2 Current context ................................................................................................. 5 1.2.1 Background ................................................................................................... 5 1.2.2 Recent activity .................................................................................................... 5 1.3 Health Protection Planning................................................................................ 8 1.4 Risks and Challenges ....................................................................................... 8 1.5 Capacity and Resilience ................................................................................. 10 1.5.1 Staffing .......................................................................................................... 10 1.5.2 Risk and mitigation ........................................................................................ 11 1.6 Supporting information .................................................................................... 12 Section 2: National and local Health Protection priorities .............................................. 13 2.1 Scotland’s Public Health priorities ................................................................... 13 2.2 Scotland’s Population Health Framework ....................................................... 13 2.3 Scottish Health Protection Network (SHPN) ................................................... 14 2.4 Horizon scanning ............................................................................................ 14 2.2 Local Priorities ................................................................................................ 16 Section 3: Review.......................................................................................................... 24 3.1 Review of Joint Health Protection Plan 2023-25 ............................................. 24 3.2 Review of Standard Operating Procedures, Protocols and Plans ................... 44 Section 4: Appendices ................................................................................................... 45 4.1 Appendix 1: List of joint NHS/Council Plans.................................................... 45 4.2 Appendix 2: Designated Competent Persons under the Public Health etc. (Scotland) Act 2008 ................................................................................................... 46 4.3 Appendix 3: Supporting information ................................................................... 48 4.3.1 Health Protection ........................................................................................... 48 4.3.2. Overview of NHS Highland and its Local Authority partners ........................ 49 4.3.3 Resources and Operational Arrangements for Health Protection .................. 50 4.3.5 Emergency Planning and Service Continuity................................................. 54 References .................................................................................................................... 59 Page 144
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Joint Health Protection Plan 25-27 v1.0 Page | 3 Introduction The Public Health etc. (Scotland) Act 2008 requires NHS Boards, in consultation with Local Authorities, to produce a Joint Health Protection Plan (JHPP) which provides an overview of health protection priorities, provision and preparedness for the NHS Board area. Guidance on the content of JHPPs has been published by the Scottish Government.1 This is the sixth Highland JHPP, with the first plan being published in 2010. This updated plan covers the period September 2025 to December 2027. It is a public document and is available to members of the public on the NHS Highland website and on request. We hope that you will find this plan to be of interest, and of value, and that its production will contribute to protecting the health of the people who live, visit and work in the Highlands and Argyll & Bute. Signed: ……………………………… Dr Jenny Wares Consultant in Public Health Medicine (Health Protection) NHS Highland, Assynt House, Beechwood Business Park, Inverness, IV2 3BW. …………………………….. Mr Alan Morrison Senior Manager -Regulatory Service and Building Standards Argyll & Bute Council, Kilmory, Lochgilphead, PA31 8RT. …………............................. Mr Alan Yates Strategic Lead - Environmental Health & Bereavement Services The Highland Council, 38 Harbour Road, Inverness, IV1 1UF. Page 145
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Joint Health Protection Plan 25-27 v1.0 Page | 4 Section 1: Overview 1.1 The Joint Health Protection Plan This plan has been created following the requirements set out in the Public Health etc. (Scotland) Act 2008. NHS Highland, Argyll and Bute Council and Highland Council have prepared this plan in collaboration and consultation. This plan is herewith referred to as the Joint Health Protection Plan (JHPP). This updated plan relates to the period September 2025 to December 2027. The plan requires to be formally approved by the NHS Highland Board and the appropriate Committees of each of the local authorities. The plan has been developed in accordance with national guidance. The purposes of the plan are: • To provide an overview of health protection priorities, provision and preparedness for NHS Highland, Highland Council and Argyll & Bute Council. • To outline the joint arrangements which Argyll and Bute Council, Highland Council and NHS Highland have in place for the protection of public health. • To improve the level of preparedness to respond effectively to a health protection incident and emergency. • To clarify the priorities for the period of the plan 2025 – 2027 and to summarise the outputs of the previous JHPP. • To identify the resources which are required to meet the plan. • To detail the liaison arrangements between NHS Highland, the two Local Authorities and other Agencies (e.g. Scottish Water, SEPA etc.). • To develop learning across the agencies. • To provide a mechanism for reviewing and recording outcomes and achievements. The delivery of the plan will be subject to review at regular meetings. These meetings will review progress, revise priorities and consider emerging issues. Minor changes may be made to the plan as required without reference to the NHS Highland Board and the appropriate Committees of each of the local authorities. The plan and its delivery will be formally reviewed and updated every two years in accordance with the legislation. Page 146
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Joint Health Protection Plan 25-27 v1.0 Page | 5 1.2 Current context 1.2.1 Background Health Protection is an area of public health that is responsible for the surveillance, prevention, investigation and management of communicable diseases and environmental hazards in addition to incident and outbreak management. The outcome of this is that the population’s health is protected from infectious and environmental threats and major incidents and that across our communities, health inequalities are reduced. Health Protection Teams (HPTs) within NHS Health Boards, work in partnership with Environmental Health teams and other partners to support this area of work. The strong working relationships have been fostered through many years of partnership working and evidenced through the development of previous Joint Health Protection Plans which demonstrates the effectiveness and importance of this JHPP process and document as part of routine working but also as part of preparedness activity. 1.2.2 Recent activity Over the period of this JHPP, in addition to expected trends in infections, we have seen exceptional levels of some infections as detailed below. Respiratory infections and vaccine preventable diseases: From a respiratory perspective, the incidence of influenza reached exceptional levels during the 2024/25 season which led to very high levels of hospitalisations secondary to influenza. In addition to the impact on hospitalisation rates, the increased incidence also impacted on our most vulnerable settings with outbreaks of infection affecting our care homes. There is ongoing infection prevention and control education and training being undertaken to support care home staff and care at home staff from an infection, prevention and control perspective. Over the course of the plan, an increase has been seen with respect to the incidence of highly pathogenic avian influenza (HPAI) with devastating effects on our wild bird populations in 2023. Whilst we managed many potential exposures to avian influenza, we did not identify any human cases of avian influenza. The three agencies have worked closely in conjunction with other partners to increase our preparedness to respond to a suspected or confirmed case(s), support both the response to detections of HPAI in wild birds the safe removal of bird carcasses where applicable, and ensuring that poultry keepers recognise the importance of having good biosecurity measures in place and other legislative measures Page 147
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Joint Health Protection Plan 25-27 v1.0 Page | 6 Although discrete cases of meningococcal infection and invasive group A streptococcal infection have been identified, we have not identified any clusters or outbreaks over the period of the plan. Whilst cases of measles have been very rarely notified across Scotland in recent years, the number of cases and outbreaks has increased significantly across parts of the UK over the past couple of years. The increased incidence over 2024 was principally seen in areas of England with almost 3,000 cases notified (n=2,911 laboratory confirmed cases).2 Across Scotland, there were 24 laboratory confirmed cases in 2024 and one case in 2023. Thus far this year in Scotland there have been 28 laboratory confirmed cases of measles (as of 27th August).3 Whilst the incidence across Scotland has increased this year, the increase has been driven by a number of clusters. This increased incidence of measles is in the context of an increased incidence and outbreaks globally compounded by declining vaccination uptake rates. This necessitates ongoing vigilance and preparedness given the potential for importation of infection and the need to prevent a resurgence of measles locally. Considerable work has been undertaken from a preparedness perspective although an area necessitating further work is that of supporting MMR uptake. It has been recognised that the pandemic disrupted established infection trends. After a period of low incidence during and following the pandemic, there was a significant increase in pertussis (whooping cough) seen from late 2023. This continued into 2024 with over 7,000 laboratory-confirmed cases of pertussis across Scotland in 2024 (n=7,051). This was higher than the annual case numbers associated with the last significant outbreak of pertussis in Scotland in 2012/13 with 1,896 and 1,188 laboratory- confirmed cases in 2012 and 2013 respectively.4 Gastrointestinal infections: Over the period of the plan, we have not identified any local outbreaks of infection and the notifications of salmonellosis, cryptosporidiosis and Shiga Toxin-producing Escherichia Coli (STEC) have been within seasonally expected trends. There continues to be close partnership working across the agencies in response to cases of infection to support source investigation and the prevention of further cases. Bloodborne viruses including hepatitis C (HCV): Within Scotland, the Scottish Government made a commitment to treat more people with hepatitis C with the aim of eliminating HCV infection and HCV related severe disease and death as a major public health concern in Scotland by the end of the 2024 financial year. This was an ambitious target which sought to achieve elimination six years ahead of the target set by the World Health Organisation. Page 148
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Joint Health Protection Plan 25-27 v1.0 Page | 7 Despite the ever-expanding treatment options, a significant proportion of HCV cases remain undiagnosed. The high proportion of undiagnosed cases, combined with the increasing range of HCV therapeutics underlies the need for effective approaches to awareness raising, HCV case-finding, re-engagement and scale-up of treatment and care. This work is being coordinated through the NHS Highland BBV Managed Clinical Network. National treatment targets have been set by Scottish Government for NHS Boards. The HCV treatment target for 2024/25 for NHS Highland was 67 based on a national target of 2,500. Whilst we did not meet our treatment target, we did achieve a significant increase in annual initiates compared to 2023/24. For 2024/25, we achieved a total of 61 initiates which equates to 91% of our board treatment target. The elimination goal for Scotland as a whole was not met but that the progress for Highland was very positive when compared across boards. In order to support elimination locally, the MCN is progressing a range of actions pertaining to case-finding, testing, awareness-raising, access to care and research and monitoring. One of the projects we implemented to support an increase in testing was a pilot project of opt-out blood borne virus testing in the emergency department. This was undertaken at Raigmore Hospital Emergency Department. This project was enabled through additional funding received from Scottish Government following a successful bid for funding. The aim of the project was to increase our case-finding activity for all three BBVs through an increase in testing. A further benefit is that testing on an opt-out basis in an Emergency Department setting would also provide more information in relation to how prevalent these infections are in addition to raising awareness of BBVs with staff and the public. As part of this project, everyone aged 16 and older who had a blood test performed as part of their assessment in the Raigmore Emergency Department received a test for Hepatitis B, Hepatitis C and HIV unless they opted-out. This project has been completed and is currently being evaluated. The MCN is committed to supporting elimination of BBVs going forwards and will continue to progress actions to increase testing, promote case-finding and to support patients into care. Local Authority Environmental Health Local authorities have seen an increase in statutory work to be carried out, resulting in new demands/pressures on existing resources. Workload has required to be reprioritised according to risk. This additional work includes short-term let licensing and enforcement, animal welfare licensing, additional responsibilities for health and safety enforcement in care homes, and responding to incidents including weather/storm/wildfire related incidents or formal enforcement activities Page 149
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Joint Health Protection Plan 25-27 v1.0 Page | 8 1.3 Health Protection Planning The prevention, investigation and control of communicable diseases and environmental hazards require specialist knowledge and skills. These include risk assessment, risk management and risk communication amongst others. These specialist skills and knowledge are applicable to a wide range of potential incidents or scenarios and are often facilitated by the existence of agreed plans and procedures for specific diseases or situations. There are many such national and local plans. Effective working arrangements are in place to support partnership working between NHS Highland and the environmental health services within Argyll and Bute Council and Highland Council. This is evidenced through work undertaken to develop common plans to ensure a systematic and consistent approach to tackling common public health issues and learning from best practice in both local authority areas and has been demonstrated through the approach taken to the pandemic response. A list of the plans which are common to all three agencies is included within appendix 1. Although excellent working relationships were already in place, the pandemic response necessitated even closer working, and more regular meetings were convened to support effective communication and information sharing between the three agencies. This forum was felt to be very beneficial for sharing information and has been retained on an ongoing basis on a bimonthly basis. 1.4 Risks and Challenges The geographical profile of the area presents several challenges to effective and timely management of a health protection incident. This poses a risk to the delivery of the service and further emphasises the importance of local knowledge and effective working relationships to an incident response. From an NHS Board perspective, the NHS Highland Board is the largest board in Scotland covering an area of 32,560km2 and accounting for 42% of Scotland’s land mass. This vast geographical area means that travelling arrangements must be factored into the planning of a response to an incident. This is particularly the case for island communities where access is dependent on ferries. There are 36 inhabited islands across both council areas. Many communities are remote and can be isolated, particularly during periods of adverse weather or, secondary to more limited transport such as a result of breakdowns or availability of ferries. The maps of the area are provided in Appendix 3. All three agencies are heavily dependent on effective telecommunications systems and a poor telephone network coverage is a problem in some remote areas and some island communities although this is improving. The response to a public health incident could Page 150
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Joint Health Protection Plan 25-27 v1.0 Page | 9 be compromised in the event of a significant failure of the telecommunications system although MS teams is increasingly used to support communications. It is important to note that a significant failure of the telecommunications system would have far-reaching consequences across organisations and would not be limited to health protection and is addressed within business continuity planning. Very infrequently, staff from all three agencies may be required to travel to the site of a public health incident. This may necessitate several hours of journey time, increased by the need for specific transport, availability of ferries, or adverse weather conditions. As such the duration of deployment is increased. It is accepted that any reduction in staffing for any of the agencies would impact even further on capacity to respond appropriately and timeously to health protection incidents. This can in part be mitigated by some of the communications improvements experienced in recent years. Collection and analysis of samples form a key step in the management of a disease outbreak. The specimens are routinely delivered to the regional or national laboratories by road/ferry or air. Meeting the turnaround time from submitting the sample to analysis can be challenging particularly microbiological samples. In some more urgent circumstances couriers and specialist transport including air transport should be used to reduce sample transit time. NHS Highland collates the surveillance data and information relating to disease outbreaks and environmental incidents and contributes to national surveillance work. Local Authorities have systems in place for the investigating reported cases and for the recording of investigative/monitoring work associated with health protection. These systems include in-house case management systems and also include the use of the Scottish Food Sampling Database (SFSD). The teams may also utilise Geographical Information Management Systems (GIS). NHS Boards use HPZone, an online system, which provides a standardised Health Protection IT system for national surveillance and managing cases and incidents across the country. Developments are planned to enable access to local authority environmental health teams to support joint investigations going forwards. The 2025 National Risk Register includes information on 89 risks that would have a substantial impact on the UK’s safety, security and/or critical systems at a national level. A number of these are relevant for the JHPP including water supply incidents, food contamination, poor air quality incidents, pandemic, outbreak of an emerging infectious disease, outbreak of highly pathogenic avian influenza. All three organisations have local risk registers. These highlight specific high-risk facilities, events or scenarios within each area and are also available through the Regional and Local Resilience Partnerships – West of Scotland Regional Resilience Partnership (RRP), Argyll and Bute Resilience Group, the Highlands and Islands Local Resilience Partnership (HILRP) and the North of Scotland RRP. Page 151
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Joint Health Protection Plan 25-27 v1.0 Page | 10 As identified in the latest Climate Change Risk Assessment (CCRA3)5 there are increasing risks posed by climate change with an increased risk of morbidity and mortality from extreme weather events, possible changes in indoor and outdoor air quality, vector-borne disease and an increased incidence of food poisoning and water- borne infections. There are also increasing issues arising from wildfires, water scarcity issues affecting private water supplies and supporting communities who may be affected by landslides, flooding, power outages, or other weather-related incidents The NHS Highland board area has one of the highest proportions of Private Water Supplies (PWS) with over a quarter (n=6,161; 27%) of the total number of registered PWS in Scotland occurring in the area.6 When compared to the mains supply, the health risks from the consumption of water from a PWS are higher with an increased risk of infections such as cryptosporidiosis and Shiga toxin-producing Escherichia coli (STEC). The climate change predictions of drier summers interspersed with heavy rain are likely to increase the risk of raw water contamination and increase the risk to human health of water-borne infections, or lead to water scarcity issues. Both Local Authorities have arrangements in place to support domestic users of private water supplies 1.5 Capacity and Resilience 1.5.1 Staffing Capacity and resilience continue to be ongoing challenges, particularly in response to the current pressure on all services to reduce expenditure. Human resource capacity of specialist health protection skills in NHSH, Argyll and Bute Council and Highland Council is limited although there was a temporary expansion as a result of the pandemic response. The expanded health protection function has been retained in NHS Highland although not at the same levels as that experienced during the pandemic. Appendix 2 lists the designated competent persons in terms of the Act. NHSH services are located in Inverness although cover the whole board area. The local authorities deliver their services from a number of geographical centres. This approach within each of the local authorities is an efficient use of limited human resources. However, this also creates small teams where the absence of an individual staff member stretches the resources available to respond to an incident. Whilst the likelihood is extremely low, the occurrence of two or more simultaneous incidents in different parts of the board area would present significant challenges. However, the pandemic demonstrated the success of all three services to redirect resources to critical areas of activity, and for other work to be paused meantime, based on a public health/health protection assessment There are particularly significant issues affecting local authorities, namely: Page 152
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Joint Health Protection Plan 25-27 v1.0 Page | 11 There is a national shortage of qualified Environmental Health Officers and whilst this is being discussed nationally, the situation has led to resourcing difficulties in many local authorities. The academic route to qualify as an EHO is currently very difficult with no method of new entrants training to become an EHO in Scotland. Although a replacement course is being planned, coupled with an aging profile, this is extremely challenging situation to sustain the workforce. Argyll and Bute have long-term EHO vacancies and whilst new career pathways have been developed enabling progression from authorised officer to EHO, this impacts directly on resilience and capacity of environmental health services. Accordingly, the challenge is to direct local authority resources to priority areas, at the expense of low risk statutory activities. Similarly, in Highland, the team have completed a workforce planning review in 2025 to improve career pathways and provide a sustainable structure. In Highland three existing technical officers are training to be EHOs with one student to qualify in 2026, and two qualifying in 2027. Two Food Safety Officers have recently completed their training and have successfully passed their professional qualifications. An increasing workload with higher demands and expectations of customers and other agencies. This includes new legislative duties which included animal welfare licensing, short term let licensing in the last two years, and new duties proposed including non- cosmetic procedures Argyll and Bute Councils Regulatory Services carried out a service review in 2024 to align it to current and emerging work and challenges, Public Services financial pressures continue to be challenging and impact directly on service provision and priorities. 1.5.2 Risk and mitigation The nature of smaller teams in our smaller board areas is not unique to health protection nor to the three respective agencies within this plan. Staff from the wider department of public health are utilised as required in a large incident in addition to staff from other teams/departments in NHS Highland as needed. Formal arrangements for mutual aid with other NHS Boards in the North of Scotland and also NHS Greater Glasgow and Clyde are in place and reviewed through the resilience procedures. Informal arrangements for mutual aid exist within the local authorities and act to support the provision of the service in remote and isolated areas. There is enhanced risk that low risk activities and businesses may become a higher risk to public health through inadequate management etc., and that these will not be Page 153
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Joint Health Protection Plan 25-27 v1.0 Page | 12 identified and corrected via routine inspections by environmental health services. There are a number of other preventative measures in place to mitigate this risk through: • Provision of advice and guidance to business and individuals • Targeted, intelligence led interventions, and liaison with other partner agencies Notwithstanding this increased risk, priority will always be given to responding to public health incidents and cases of suspected or confirmed communicable disease, by redirecting resources to these investigations. 1.6 Supporting information Appendix 3 provides the following background information in support of the plan: • Health Protection definitions • Overview of NHS Highland and its local authority partners • Resources and operational arrangements for Health Protection • Emergency Planning and Business Continuity • Inter-organisation collaboration and mutual aid • Out-of Hours arrangements • Maintenance of competencies for Health Protection staff • Public Feedback Page 154
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Joint Health Protection Plan 25-27 v1.0 Page | 13 Section 2: National and local Health Protection priorities 2.1 Scotland’s Public Health priorities As part of Public Health Reform the Scottish Government and COSLA, working with a range of partners and stakeholders, developed a set of public health priorities to improve Scotland’s health. The following priorities were published in 2018 and provide a ten year focus for improving the health of the nation. Table 1: Scotland’s Public Health priorities Priority 1: A Scotland where we live in vibrant, healthy and safe places and communities Priority 2: A Scotland where we flourish in our early years Priority 3: A Scotland where we have good mental wellbeing Priority 4: A Scotland where we reduce the use of and harm from alcohol, tobacco & other drugs Priority 5: A Scotland where we have a sustainable, inclusive economy with equality of outcomes for all Priority 6: A Scotland where we eat well, have a healthy weight and are physically active It is acknowledged that the priorities do not reflect all of the activities that contribute to the health of Scotland’s communities and that many activities are included in the broader public health reform work but not explicitly reflected. The report7 on Scotland’s six public health priorities states how, ‘our work to protect the health of the population from serious risks and infectious diseases through vaccination, infection control and incident response (health protection), will continue to be an essential public health function and must be maintained. We will not compromise our existing, high-quality protections and our ability to respond to emerging threats.’ 2.2 Scotland’s Population Health Framework In recognition of the need for a renewed and long-term focus on prevention across all areas that affect health, Scotland’s Population Health Framework has been developed. This sets out the collective approach to improving health and reducing health Page 155
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Joint Health Protection Plan 25-27 v1.0 Page | 14 inequalities which emphasises the shift towards prevention and early intervention. Initial actions from a health protection perspective include: Housing Support the contribution of better housing to health. Climate Change and Nature Maximise efforts to tackle the climate and nature emergencies given the close links between environmental and human health. Vaccination and Immunisation Deliver the actions of the Scottish Vaccination and Immunisation Programme (SVIP) 5 Year Framework and Delivery Plan (2025-2030). Health Protection Support better health protection in Scotland. Sexual Health and Blood Borne Viruses Progress delivery of improvements to sexual health and wellbeing. 2.3 Scottish Health Protection Network (SHPN) The Scottish Health Protection Network (SHPN) is an obligate network of existing professionals, organisations and groups within the health protection community across Scotland. In line with the stated aims, the SHPN supports the development, appraisal and adaptation of health protection guidance, seeking excellence in health protection practice. The shared ownership of the network is one of its key strengths and all three organisations contribute to the collective work of the network. Many of the work-streams of both the HPT and the environmental health teams are directed by the work of the SHPN and all three teams are committed to continuing to support the work of the network. Furthermore, the Chief Medical Officer and Scottish Government have previously identified various national health protection priorities as detailed within table 3. NHS Highland JHPP commits to meeting these in the term of this plan. 2.4 Horizon scanning It is vital that we take a horizon-scanning approach to ensure that we are well prepared for likely future threats or areas of increasing workload. Areas that will require further work in future years include: • Preparedness in relation to vector-borne diseases (VBDs): The epidemiology of vector-borne diseases is evolving across the world, including the UK and Europe, in the context of climate change which has expanded the geographic range of environments suitable for mosquito and tick populations. From a UK perspective, Page 156
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Joint Health Protection Plan 25-27 v1.0 Page | 15 the bacteria causing Lyme disease and the virus causing Tick-borne encephalitis (TBE) are now endemic in ticks and Usutu virus (USUV) is endemic in mosquitoes. In addition, there is some evidence of West Nile Virus (WNV) detection in mosquitoes in the UK. Whilst the risk posed by VBDs to human health in Europe and the UK is difficult to accurately ascertain, evidence supports an increasing risk to human health from vector-borne diseases. • Increasing globalisation and international travel has led to an increase in the risk of imported diseases such as Middle East Respiratory Syndrome Coronavirus (MERS-CoV) and Viral Haemorrhagic Fevers (VHFs) such as Ebola. This risk is likely to increase in the future. • Re-emergence of ‘eliminated’ diseases as seen with the outbreak of measles seen across parts of England in recent years. • Climate change is likely to result in more frequent and intense extreme weather events in addition to the impacts of water scarcity. • Declining vaccination rates and a rise in risk from the global ‘anti-vaccination’ movement which the World Health Organisation listed as one of its top ten threats for 2019 and which continues to pose a threat to health. • Following the COVID-19 pandemic, we know that the world will face another pandemic. What we don’t know is when this will be and how severe it would be which necessitates ongoing pandemic preparedness across organisations. • Regulation of non-surgical cosmetic procedures which is an industry which has expanded significantly in recent years. There is currently no regulation of non- surgical cosmetic procedures although Scottish Government recently undertook a further consultation on the licensing and regulation. This has resulted in proposed legislation with implementation being explored. • Food Safety. Food Standards Scotland are leading the SAFER project to develop a new approach to food enforcement in Scotland whilst ensuring that food safety and public health is protected. • Housing – proposed legislation to improve energy efficiency in the private rented sector (Minimum Energy Efficiency standards (MEES) • Utilising digital technologies, including a pilot to extend the use of HPZone, an online system, which provides a standardised Health Protection IT system for national surveillance to local authority environmental health teams. This will support joint investigations. Page 157
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Joint Health Protection Plan 25-27 v1.0 Page | 16 2.2 Local Priorities Health Protection is a core part of the services delivered by NHS Highland through the Public Health Department’s HPT and both Argyll & Bute and Highland Councils through the protective services remits (environmental health, trading standards, licensing standards and animal health and welfare). This plan recognises that work is undertaken on a daily basis relating to the following areas of responsibility and service delivery: • Protecting public health; • Preventing the spread of communicable diseases in the community; • Improving standards of food safety; • Ensuring safe and potable drinking water supplies; • Improving standards of workplace health and safety standards; • Promoting a safe environment and protecting the public from environmental hazards; • Providing safe private and short term let accommodation; • Ensuring adequate plans are in place to respond to incidents and emergencies. In addition, a number of local health protection priorities requiring joint action have been identified which also acknowledge the need to address the current national health protection priorities. The local priorities, which are detailed in table 3 below, will be progressed through the incorporation within the operational service plans of each Local Authority or NHS Highland, and where they are common, delivered through effective working and partnership between the agencies. It has also been recognised that there is a need to increase the visibility of health protection and the impact that the function has to support wider awareness raising with stakeholders. In light of the current financial challenges, there is also a need to better demonstrate the return on investment provided by the work of the service. This is a shared priority across each of the three agencies and will be progressed within the time- frame of the plan. Page 158
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Joint Health Protection Plan 25-27 v1.0 Page | 17 Table 2: National and Local Priorities Source Outcome Work plan Agencies Involved 1. National priority Support the contribution of better housing to health • Utilise Private Landlord Registration scheme to assist with improving housing conditions in the private rented sector and reducing antisocial behaviour. • Continue working on strategies to improve housing conditions including licensing of HMOs and residential mobile home sites. • Ensure that properties provided for short-term let are safe for use, have adequate facilities and do not adversely impact on communities. • Engage on proposed legislation to improve energy efficiency in the private rented sector (Minimum Energy Efficiency standards (MEES) Highland Council Argyll & Bute Council 2. National priority Maximise efforts to tackle the climate and nature emergencies given the close links between environmental and human health. • Work together to mitigate the effects of climate change. Some of the specific examples include supporting the response to water scarcity events in addition to supporting the public health response to wildfires. • Continue to support the implementation of renewable energy installations and the response to concerns regarding health impacts of developments., including windfarms and battery storage sites NHS Highland Highland Council Argyll & Bute Council 3. National priority Reduce Vaccine Preventable Diseases The delivery within NHS Highland contributes to Scotland’s Vaccination and Immunisation Programme (SVIP) and Scotland’s over-arching mission to deliver a world- leading, person-centred and public health led vaccination and immunisation service. Our local objectives align to the goals set out within Scotland’s 5-year vaccination and immunisation framework and the vaccination standards set for NHS Boards as part of the Annual Delivery Plan. There are recognised inequalities with respect to immunisation programmes with uptake rates lower in more deprived communities with reducing inequalities a key aim for all involved in immunisation programmes. • Ensure models of delivery are targeted to support increased uptake across our hard- to-reach groups and underserved populations in order to address existing health inequalities • Deliver the Vaccination Transformation Programme by implementing models of delivery that fit a rural area and ensure continued high levels of vaccine uptake in all childhood and adult programmes. • Develop and implement a local plan for delivery of the SVIP Five Year Vaccination and Immunisation Framework • Implement the national childhood schedule change at a local level. NHS Highland Highland Council Argyll & Bute Council Page 159
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Joint Health Protection Plan 25-27 v1.0 Page | 18 4. National priority Progress action towards elimination of Hepatitis C (HCV), Hepatitis B (HBV) and HIV As detailed earlier, the Scottish Government has made a commitment to treat more people with hepatitis C with the aim of eliminating HCV infection and HCV related severe disease and death as a major public health concern in Scotland. The high proportion of undiagnosed cases, combined with the increasing range of HCV therapeutics underlies the need for effective approaches to awareness raising, HCV case-finding, re- engagement and scale-up of treatment and care. This work is being coordinated through the NHS Highland BBV Managed Clinical Network. National treatment targets have been set by Scottish Government for NHS Boards. The HCV stretch target for 2025/26 for NHS Highland is 67. • Coordinate actions to support the achievement of NHS Highland’s stretch target for HCV. • Finalise the draft local strategy and action plan for the elimination of hepatitis. • Implement actions to support HIV transmission elimination. NHS Highland Highland Council Argyll & Bute Council 5. National priority Reduce the incidence of tuberculosis (TB) The Scottish Government has commissioned a review of TB services in Scotland which has been delivered by the Royal National Orthopaedic Getting It Right First Time Projects Directorate (RNOH/GIRFT). The core principle of the programme is a clinically led, peer-to-peer review, data driven approach to healthcare improvement. Information from each TB service provider, through completion of an in-depth survey, has been collected to enable an analysis of the service provision in Scotland. This was collated and analysed alongside the TB surveillance data. Following this, a data-pack was developed and used to support a deep dive visit locally. This was very positive and a report has been developed for NHS Highland. • Consider the recommendations of the local report in the context of the national recommendations and develop an implementation plan. NHS Highland 6. National priority Support better health protection in Scotland A group has been convened to develop a consensus position statement for health protection which will include the key areas for priority action going forwards. This is in the context of the publication of the population health framework. The group is a multidisciplinary group with input from HPTs, EHOs, PHS and DsPH with geographical representation included. • Support the implementation of any recommendations of the position statement. NHS Highland Highland Council Argyll & Bute Council 7. National priority Addressing health inequalities (in addition to actions within other priority areas) • Review approaches to incivilities to identify good practice and specific projects to implement. Incivilities can include issues such as vandalism, graffiti, litter, dog-fouling and fly-tipping. • Implement short term let licensing regimes with the aim of securing safety within premises used for this purpose and safeguarding communities • Support Resettlement Programs to ensure that accommodation provided is safe and has adequate facilities and services. • Support the empty homes strategy aimed at encouraging improvements to properties in order to bring them back into housing use. Highland Council Argyll & Bute Council Page 160
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Joint Health Protection Plan 25-27 v1.0 Page | 19 8. National priority Monitoring and Improving drinking water quality • Collaboration between all three agencies and Scottish Water in the monitoring and improvement of public and private water supplies. • Work with DWQR to deliver the requirements on Private Water Supplies. • Deliver a joint training day between all three agencies and Scottish Water to support the education and training of all stakeholders. • Work with stakeholders to implement the DWQR requirements in relation to perfluoroalkyl and polyfluoroalkyl substances (PFAS) NHS Highland Highland Council Argyll & Bute Council 9. National priority Food control • Ensure effective communication routes of communication for rapid dissemination of alerts regarding food-borne infections • Continue to raise awareness of the health implications of glycerol and to ensure that businesses are aware of the FSS guidance. • Reinstate food control enforcement services and deliver a range of food interventions in respect of the national Food Safety Code of Practice. • Working with FSS, develop a new approach to food enforcement in Scotland (SAFER) whilst ensuring that food safety and public health is protected. • Continue to contribute to and support both national and local food surveillance programmes NHS Highland Highland Council Argyll & Bute Council 10 National and local Public Analysts Services • Monitor the Improvement Services review of Scottish Local Authority Public Analyst Services and consider the impact to local authority service provision Highland Council Argyll & Bute Council 11 National and local Regulation of non-cosmetic procedures • Scottish Government propose to issue legislation to regulate this sector, with responsibility for specific sectors falling to local authorities. Councils require to implement these new licencing and enforcement regimens Highland Council Argyll & Bute Council 12. National priority Control Environmental exposures which have an adverse impact on health • Tackle the effects of antisocial or excessive noise in the community. • Deliver on air quality standards within each local authority area. • Review approaches to swimming pools and spas to ensure appropriate controls are in place regarding infection control. • Blue-green algae - Promotion of safe usage of recreational waters where there is a risk of BGA, implementation of permanent signage and responding to incidents that occur. • Progress Contaminated Land strategies and ensure land is made suitable for use through development management. • Monitoring of bathing water quality (designated beaches/lochs) with SEPA. • Apply the regulations for legionella safety in public buildings. NHS Highland Highland Council Argyll & Bute Council Page 161
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Joint Health Protection Plan 25-27 v1.0 Page | 20 • Monitor the levels of lead in private water supplies and assist properties on mains supplies to encourage owners/users to carryout repairs to remove/reduce the lead contamination risks and improve water quality. 13. Local priority Resilience to respond to pandemics through effective multi-agency response • Implement the ongoing learning from the pandemic as this is developed. • Review business continuity plans and pandemic plans in light of the learning from the COVID-19 pandemic NHS Highland Highland Council Argyll & Bute Council 14. Local priority Effective sea and airport health plans to provide adequate disease control measures • Review existing sea and airport health plans across Argyll and Bute Council and Highland Council to include arrangements for any imported disease. • Hold a desktop exercise to test these plans. NHS Highland Highland Council Argyll & Bute Council 15. Local priority Enhance recovery planning for a major incident • Review and further develop the generic Recovery Plan outlining multi-agency responses. • Exercise recovery plan for major flood or events. • Contribute to Regional Resilience Partnerships. • Continue implementation of Care for People guidance. NHS Highland Highland Council Argyll & Bute Council 16. Local priority Ensure effective surveillance is in place which supports local and national needs • Develop and circulate a survey for stakeholders with respect to surveillance needs to ensure that these are best met for ongoing surveillance and monitoring of communicable diseases • Continue to monitor the performance of current surveillance and reporting activity. NHS Highland 17. Local priority Effective and proportionate arrangements in place to protect public health • Revise joint health protection policies and procedures between all three parties as appropriate. • Review existing arrangements/plans as a routine part of each incident that occurs. • Undertake specific exercises for the purposes of training and evaluation of contingency plans relating to water and waste-water incidents and the recovery phase following a radionuclide incident. • Consider key performance standards for the response, investigation and actions for public health incidents • Joint training in managing incidents/outbreaks and chairing these meetings such as STAC. • To investigate and take appropriate action in response to service requests which have the potential to impact adversely on the environment or to public health. • Joint protocol to be devised to manage vulnerable individuals displaying hoarding behaviour or whose lifestyle behaviour affects others. • Collate the objectives underpinning the workplan to support joint monitoring across the agencies. NHS Highland Highland Council Argyll & Bute Council Page 162
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Joint Health Protection Plan 25-27 v1.0 Page | 21 18. Local priority Minimise the risk to the public from Lyme Disease and other vector-borne diseases • Assist with ongoing research and reviews. • Continue to raise public awareness. • Review and develop websites/links to provide suitable information. NHS Highland Highland Council Argyll & Bute Council 19. Local priority Reducing the impact of tobacco, alcohol and other harmful substances on public health • Continued regulation of the smoking ban in enclosed and public places including NHS premises. • Continued work with licensed trade in respect of responsible drinking and minimum pricing. • Continue regulatory work on age-related sales activity of cigarettes, and other products. • Promotional campaign targeted at reducing the under-age sale of tobacco and vaping products to children and young adults. • Joint working with the police relating to the sale of Novel Psychoactive Substances (NPS). NHS Highland Highland Council Argyll & Bute Council 21 Local priority Strong and Safe Communities • To investigate and implement effective controls to minimise the spread of suspected and confirmed cases of communicable and notifiable diseases in the community. • The protection of the vulnerable in communities from the impact of cold calling and rogue traders. NHS Highland Highland Council Argyll & Bute Council 21. Local priority Radon protection • Ensure that the public in radon affected areas are provided with adequate information relating to the risks of radon and the mitigation measures which can be taken to reduce the risk. • Raising awareness of radon monitoring responsibilities to employers and landlords. • Produce a Radon Strategy for ABC to include council owned property and rented property. • Ensure Radon awareness through development management. NHS Highland Highland Council Argyll & Bute Council 22. Local priority Education and advice programme • Develop a communications calendar which includes communication drafts and templates which can be used at different points in the year to raise public and professional awareness of hazards and preventative actions to take • Raising awareness of the Outdoor Code and communicable disease and controls through improved public information. • Development and review of existing information leaflets and improvements to website. • Increase awareness of health protection issues with local businesses through use of alternative enforcement plans. NHS Highland Highland Council Argyll & Bute Council Page 163
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Joint Health Protection Plan 25-27 v1.0 Page | 22 23. Local priority Preventing and minimising the spread of infection • Investigation of suspected and confirmed cases of communicable disease and implementation of appropriate controls to prevent further spread. • Monitoring trends by enhanced surveillance and reporting. • Implement the national microbiology strategy locally and ensure appropriate access to testing in the public analyst labs. • Ensure public health actions are taken to minimise risks from zoonotic infections reported by Scottish Veterinary Service (SVS). • Ensure animal related visitor attractions present safe environments for all visitors NHS Highland Highland Council Argyll & Bute Council 24. Local priority Food safety priorities • To undertake the duties as statutory Food Authority in protecting food safety in the food industry and deliver the Councils’ Food Safety Law Enforcement Work plan. • Work with FSS and other partners to develop a new approach to food control enforcement in Scotland (SAFER) whilst ensuring that food safety and public health is protected. • Work nationally with relevant LA partners and the FSS to ensure FBOs manufacturing unpasteurised cheese are safe to do so considering the E.Coli STEC & L. monocytogenes risks. • Continue to work with the FSS/SFELC and relevant LA partners to improve the verification of FCMs in FBOs who manufacture cold smoked fish contributing to national response to the UK wide outbreak Highland Council Argyll & Bute Council 25. Local priority Health and safety at work initiatives • To complete the Councils’ Health and Safety at Work Law Enforcement Plan. Highland Council Argyll & Bute Council 27 Local priority Horizon Scanning and Emerging Infections • Be aware of new and emerging infections and plan how to minimise their impact locally. • Implement the forthcoming legislation of non-surgical cosmetic procedures. NHS Highland Highland Council Argyll & Bute Council 28. Local Priority Animal health and zoonoses • Respond to current and emerging diseases such as the risks from avian influenza. • Deal with the illegal import of animals. • Carry out animal health and welfare enforcement activities in accordance with Framework Agreements. • Improve preparedness to deal with animal health disease outbreaks. • Work with PHS to implement the Q-fever SOP and deliver additional education to support this locally. NHS Highland Highland Council Argyll & Bute Council 29. Local Workforce planning and resilience • Training and support in incident management and response including STAC • Support the development of Environmental Health Officers and other professional staff within Council services as part of our workforce strategy, to provide adequate capacity and resilience NHS Highland Highland Council Argyll & Bute Council 30. Local Water safety plans • Promote water safety through Water Safety Partnerships with other agencies • Review water based activities to promote safety for all involved. NHS Highland Highland Council Argyll & Bute Council Page 164
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Joint Health Protection Plan 25-27 v1.0 Page | 23 31. Local Coordinated approach to public health • Progress proposal to pilot Epi-Q on HPZone • Actively participate in the national Scottish Health Protection Network and associated governance groups to promote a coordinated approach to protecting public health and developing new guidance and systems. NHS Highland Highland Council Argyll & Bute Council 32. National/L ocal Housing Emergency • Delivery of Housing Emergency Action plans Argyll & Bute Council 33 National and local Serious and Organised Crime • Work with other regulators to target activity to detect and disrupt organised crime and risks to public health/health protection Highland Council Argyll & Bute Council Page 165
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Joint Health Protection Plan 25-27 v1.0 Page | 24 Section 3: Review 3.1 Review of Joint Health Protection Plan 2023-25 In preparing the JHPP 2025-27, we have considered the findings of the review of the previous JHPP. This review identified that work has progressed well against the plan with good progress noted against almost all of the national and local priorities. The established working arrangements, promoted through this plan, proved to be effective in responding to communicable disease outbreaks and general incident management (e.g. blue-green algae, drinking water incidents) Some priorities have not been fully addressed due to new or emerging priorities or resourcing issues. These have been reviewed and whether appropriate and relevant, are included in the 2025-27 Joint Health Protection Plan. The program to review joint policies and procedures was not progressed, as planned, due to lack of available resources across all three agencies. On refection, the lack of having an agreed timetable over the duration of the plan, resulted in these reviews being delayed In reviewing the 23-25 plan and achievements, a number of actions were identified to how we deliver the plan in the future. o Provide a more structured timetable for the review of joint procedures. This provides a focus, supports resource deployment; and aids monitoring of the plan. It is proposed that all agencies meet on approval of the Plan, to implement this approach o To re-establish the multiagency agency Environmental Health Liaison Group. This will build relationships with other agencies, support learning and sharing best practice, and delivery of the Joint Health Protection Plan o Regular meetings to focus solely on delivering the Plan. This will review progress, revise priorities and consider emerging issues Page 166
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Joint Health Protection Plan 25-27 v1.0 Page | 25 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Reduce Vaccine Preventable Diseases Deliver the Vaccination Transformation Programme by implementing models of delivery that fit a rural area and ensure continued high levels of vaccine uptake in all childhood and adult programmes. - - A process of significant service redesign is being undertaken to develop a collaborative hybrid model in Highland HSCP. This will involve a collaborative delivery model with input from general practice and vaccination teams. A review of existing flexibility is also being undertaken in A&B HSCP. A Reduce the incidence of tuberculosis (TB) Implement the actions within the Scottish Tuberculosis (TB) Framework including that of the development of an overarching policy for the management of latent tuberculosis. - - Scottish Government commissioned a review of TB services in Scotland using the Getting It Right First Time (GIRFT). The review was very positive for NHS Highland with excellent feedback in addition to recommendations for further consideration. In addition, a business case has been developed nationally and submitted to Scottish Government in relation to screening for latent tuberculosis. G Progress action towards Hepatitis C (HCV) elimination Implement any actions and recommendations developed as part of national SHBBV policy. One specific area of work will be updating NHS Highland’s HCV Elimination Plan. - - Funding was successfully secured to implement a blood-borne virus (BBV) opt-out testing pilot in the Emergency Department. In terms of progress against our treatment targets NHS Highland was joint top with G Page 167
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Joint Health Protection Plan 25-27 v1.0 Page | 26 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status 91% of our treatment initiate target achieved. NHS Highland also achieved the highest proportion of admissions tested in prisons when compared across all prisons in Scotland. Addressing health inequalities Utilise Private Landlord Registration scheme to assist with improving housing conditions in the private rented sector and reducing antisocial behaviour. Delivery of statutory work associated with landlord registration scheme Successful recruitment of Private Landlord Registration team to ensure suitable and continued implementation of the Private Landlord Registration scheme. Private Landlord Registration scheme well established in Highland - G Continue working on strategies to improve housing conditions including licensing of HMOs and residential mobile home sites. Service requests continue to be investigated, which can involve investigation of statutory nuisance complaints. Processing of residential caravan site and HMO licence applications. Argyll and Bute Council also declared a “Housing emergency” in June 2023 due to “consistent reduction in the supply of housing, a steady increase in demand for housing across all tenures and increasing levels of un-affordability". Work ongoing to improve housing conditions, monitor HMOs and licence residential caravan sites. Highland Council declared a Housing Challenge and agreed a number of strategic objectives in June 2024. A Housing summit was held with partners in October 2024. - G Review approaches to incivilities to identify good practice and specific projects to implement. Incivilities can include issues such as vandalism, graffiti, litter, dog-fouling and fly-tipping. LEAMS surveys completed monthly of street condition and cleanliness and these submitted to “Keep Scotland Beautiful”. Dog fouling and litter patrols regularly undertaken to target worst affected areas in Highland. Use of mobile CCTV for fly-tipping being - G Page 168
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Joint Health Protection Plan 25-27 v1.0 Page | 27 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Vandalism – targeted specific areas and have deployment of mobile CCTV. Dog fouling –ongoing promotion of responsible dog ownership and targeted enforcement. reviewed. Joint working with DVLA to target abandoned & nuisance vehicles. Implement short term let licensing regimes with the aim of securing safety within premises used for this purpose and safeguarding communities Short-term let licensing in place at 3064 licences issued. Policies revised to implement changes to legislation or improvements to the scheme In Highland over 8500 licence applications have been processed. The implementation of the scheme will continue to be a priority and requires significant resource going forward to conduct compliance monitoring, complaint investigation and licence renewals. - G Support the Ukrainian Resettlement Program and ensure that accommodation provided is safe and has adequate facilities and services. 181 property inspections completed Council wide, to ensure that properties used for the Ukrainian Resettlement program met requirements Environmental Health support the on-going Ukrainian resettlement team in conducting property inspections. - G Support the empty homes strategy aimed at encouraging improvements to properties in order to bring them back into housing use. First Council to announce Housing Emergency and action plan in place. Award winning Empty Homes team Environmental Health support the Council’s Empty Homes team - G Minimise the risk to the public from Shiga toxin-producing E. coli (STEC) infection Implement any outstanding recommendations within the VTEC Action Plan for Scotland. The guidance for STEC has been implemented and is mainstreamed into operational work. The guidance for STEC has been implemented and is mainstreamed into operational work. The guidance for STEC has been updated nationally and implemented locally. G Page 169
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Joint Health Protection Plan 25-27 v1.0 Page | 28 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Improve the safety of private water supplies and ensure that public health interventions are taken for any failing drinking water supplies, whether public or private. Risk assessments completed, “boil notice” applied as immediate intervention, investigations completed following adequate remedial action by clients. Carried out routine compliance sampling and resampling as per monitoring programme. Incident procedures in place and routine compliance sampling and resampling as per monitoring programme. Continued collaborative working to ensure potable water supplies and timely response to water quality failures. G Promotion of safe practices and procedures where there is contact with livestock at animal parks and farms Advice available on the procedures to be adopted where there is contact with livestock at farms and animal parks. Complaints were investigated and action taken. Advice available on the procedures to be adopted where there is contact with livestock at farms and animal parks. Complaints were investigated and action taken. - G Implement recommendations on the safe use of agricultural ground for recreational events. Safe use of agricultural ground for recreational events is implemented across Argyll and Bute for all events including agricultural shows, Highland Games and other festival events. Recommendations implemented. - G Investigations of cases of STEC and implementation of appropriate control measures. All cases which are notified are investigated by EH as routine workload. All cases which are notified are investigated by EH as routine workload. - G Food control Reinstate food control enforcement services and deliver a range of food interventions in respect of the national Food Safety Code of Practice. Inspection programme of food businesses serving vulnerable groups and programme of random sample of food businesses commenced. Small team of officers focus on Approved premises, to encourage detailed knowledge of high risk products. Inspection programme in place focussed on high risk premises. - G Page 170
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Joint Health Protection Plan 25-27 v1.0 Page | 29 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Working with FSS, develop a new approach to food enforcement in Scotland (SAFER) whilst ensuring that food safety and public health is protected. Engagement with FSS but national programme has been delayed Engagement with FSS but national programme has been delayed - A Scottish Veterinary Service review • Participating in the national program relating to the creation of a Scottish Veterinary Service, and the impact on local authority animal health and welfare services. Creation of Scottish SVS has been put on hold pending identification of any funding streams, meaning the formation id currently unlikely. - - G • Managing the risk relating to the possible transfer of AHW services from local authorities which will impact adversely on other statutory services relating to environmental health and trading standards. The Local Authority SVS Steering Group developed an AHW Improvement Plan which was delivered through the Animal Health and Welfare Strategy Group. G Monitoring and Improving drinking water quality Collaboration between all three agencies and Scottish Water in the monitoring and improvement of public water supplies. Continued collaborative working to ensure potable water supplies and timely response to water quality failures. Continued collaborative working to ensure potable water supplies and timely response to water quality failures. Continued collaborative working to ensure potable water supplies and timely response to water quality failures. G Page 171
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Joint Health Protection Plan 25-27 v1.0 Page | 30 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Work with DWQR to deliver the requirements on Private Water Supplies. Private water supply grant scheme in place and being delivered in Argyll and Bute. Since its inception, £2.27 million has been provided to improve private water supplies. Participation in the working group for the new lead in water guidance (“Public health management of elevated lead levels in drinking water guidance”) with SHPN Water scarcity plan and actions – Council participation in Scottish Government Scarcity Scheme in 2023, 2024 and 2025. Water provided to seven supplies in 2025 during the May dry period. 1277 commercial supplies sampled as required from the monitoring programme. 162 investigations undertaken following initial “failure” of supplies. Private water supply Improvement Grants for supplies: 16 grant applications paid in the period, issuing £29,029.05 in funds for these works. Works are going to extend grant availability for determined criteria of lead in Programme of sampling and risk assessment in place and underway. Highland has 1209 commercial supplies and 1676 domestic supplies. Environmental Health continue to support the Scottish Government water Scarcity Scheme and seeing an increase in demand for emergency bottled water in specific geographical areas. 796 commercial supplies and 76 domestic supplies sampled. 155 investigations undertaken following initial failure of supplies. 35 grants for private water supply improvements were approved with an expenditure of £42,842.90 Highland Council's private water supply grant policy was reviewed in 2023 and enhanced grant funding is available to eligible persons for carrying out improvements to their supplies, including the removal of lead and increasing supply Continued collaborative working to ensure potable water supplies and timely response to water quality failures. G Page 172
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Joint Health Protection Plan 25-27 v1.0 Page | 31 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status water, increasing supply resilience and supplies requiring additional “complex” chemistry treatment to be installed. This would enable additional monies to be issued for private water supply users. Proposals in draft for this. 148 Private Water Supply Risk assessments completed. resilience. Two enhanced grants have been awarded for resilience improvements. 556 private water supply risk assessments of commercial supplies have not been completed. This accounts for 46% of the commercial supply register. Resources continue to be focused on the risk assessment programme Control Environmental exposures which have an adverse impact on health Tackle the effects of antisocial or excessive noise in the community. Work ongoing at operational level across all areas Work ongoing at operational level across all areas G Deliver on air quality standards within each local authority area. Local Air Quality in Argyll and Bute is good and well below national standards for all the prescribed pollutants. Regular Air Quality report submitted and approved by Scottish Government. Following review and noted improvement in air quality in Inverness City Centre, the Air Quality management Area was revoked in May 2025. Continued collaborative working to support effective responses to poor air quality. G Review approaches to swimming pools and spas to ensure appropriate controls are in place regarding infection control. Assessed during inspections and other investigations Assessed during inspections and other investigations - A Blue-green algae - Promotion of safe usage of recreational waters where there is a risk of BGA, implementation of permanent Blue-green algae – Officers have assessed waters and identified where to erect permanent signage advising of Specific risk assessments completed. Permanent signage being reviewed. Timely response to incidents involving blue- green algae. G Page 173
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Joint Health Protection Plan 25-27 v1.0 Page | 32 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status signage and responding to incidents that occur. the risks and measures to take where algae growth is noted. Specific risk assessments completed Progress Contaminated Land strategies and ensure land is made suitable for use through development management. New charging regime being piloted for site investigation reports (historic industrial uses) Lead levels in public buildings- reactive approach in place Ongoing work through development control process - G Monitoring of bathing water quality (designated beaches/lochs) with SEPA. Liaison with SEPA and action as appropriate Work ongoing at operational level across all areas - G Apply the regulations for legionella safety in public buildings. Mainstreamed into Health and safety regulation Mainstreamed into Health and safety regulation - G Monitor the levels of lead in drinking water in public buildings especially schools and in relevant private establishments such as nurseries. Designated officers receive the Scottish Water “Initial Drinking Water Quality Notification Report for Event” emails and subsequent follow up to these with progress made. Contact can be made to Environmental Health service with established email channel, as with incident in October 2024, requiring Environmental Health to investigate. Team are participating and undertaking relevant work - G Control Environmental exposures which have an adverse impact on health Incidents - Participation in oil spill event whereby major oil pipeline leaked into local area served by private water supplies, with remediation work monitoring and PWS Procedures in place for significant incidents - G Page 174
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Joint Health Protection Plan 25-27 v1.0 Page | 33 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status requiring protection throughout period – now resolved. Reacted to a number of boat sinking/abandonment issues requiring action to prevent public exposure and/or food chain exposure Resilience to respond to pandemics through effective multi- agency response • Review business continuity plans and Pandemic plans in light of the learning from the COVID-19 pandemic Business continuity plans have been updated along with teams and departments across the organisation. Business continuity plans have been updated along with teams and departments across the organisation. Business continuity plans have been updated along with teams and departments across the organisation. G Effective sea and airport health plans to provide adequate disease control measures Review existing sea and airport health plans across Argyll and Bute Council and Highland Council to include arrangements for any imported disease e.g. Viral Haemorrhagic Fever Outstanding and to be included for action in 2025-27 plans Outstanding and to be included for action in 2025-27 plans - A Hold a desktop exercise to test these plans. Outstanding and to be included for action in 2025-27 plans Outstanding and to be included for action in 2025-27 plans Contribution to the national cruise ship exercise along with national and local agencies plus cruise ship operators. A Review the current situation concerning Port Health and identify whether Argyll and Bute should become a designated Port Health Authority. Outstanding and to be included for action in 2025-27 plans - - A Enhance recovery planning for a major incident Review and further develop the generic Recovery Plan outlining multi-agency responses. Radiation incident exercised at HMNB Clyde as per cyclical requirements Exercises held covering recovery including radiation incidents - G Exercise recovery plan for major flood or events. Desktop exercise (“Hawaii of The North”) for the Tiree Music Festival successfully held in Oban in March 2025. Exercise Environmental Health regularly involved in Safety Advisory Group meetings to ensure a - G Page 175
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Joint Health Protection Plan 25-27 v1.0 Page | 34 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status was designed and co- ordinated by Environmental Health and the Tiree Music Festival to test the event safety plans, emergency plans and the contingency and capacities of those in attendance to respond to emergency incidents. The Environmental Health service organise regular Safety Advisory Group meetings to ensure a multi-agency input to safety consideration of public events. multi-agency input to safety consideration of public events. Contribute to Regional Resilience Partnerships. Council responded to a number of incidents which required the implementation of the incident response and recovery. This included landslides where communities were isolated, road closures, storms (Storm Eowyn etc) and power outages. Ongoing contributions to the RRPs Ongoing contributions to the RRPs across all three agencies. G Continue implementation of Care for People guidance Guidance followed as part of major event preparations Guidance followed as part of major event preparations Guidance followed as part of major event preparations G Specific training in respect of Scientific and Technical Advisory Committees (STAC) to NHS and LA staff Specific STAC training provided to appropriate agencies as part of preparations for exercising the Offsite Plan for Faslane STAC training has been held through UKHSA. G Page 176
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Joint Health Protection Plan 25-27 v1.0 Page | 35 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Effective and proportionate arrangements in place to protect public health Revise joint health protection policies and procedures between all three parties. EH operational work ongoing and demand reduction exercises ongoing to ensure the effective use of resources. Routine procedures in place but need for review Routine procedures in place but need for review A Review existing arrangements/plans as a routine part of each incident that occurs. Briefing and implementation of learning is a standard part of incident management. Briefing and implementation of learning is a standard part of incident management. Briefing and implementation of learning is a standard part of incident management. Undertake specific exercises for the purposes of training and evaluation of contingency plans relating to water and waste-water incidents and the recovery phase following a radionuclide incident. Radionuclide incidents exercised but exercises for water and waste-water incidents not undertaken Radionuclide incidents exercised but exercises for water and waste-water incidents not undertaken It was not possible to deliver the exercise within the time-frames of the plan but there is an exercise being planned in relation to water and waste-water incidents. A Consider key performance standards for the response, investigation and actions for public health incidents Key performance standards for the response, investigation and actions for public health incidents not progressed Key performance standards for the response, investigation and actions for public health incidents not progressed Key performance standards for the response, investigation and actions for public health incidents not progressed R Joint training in managing incidents/outbreaks and chairing these meetings such as STAC. Joint STAC Training provided by NHS Highland Joint STAC Training provided by NHS Highland Joint STAC Training provided by NHS Highland G To investigate and take appropriate action in response to service requests which have the potential to impact adversely on the environment or to public health Response to service requests requiring investigation by Officers. Officers authorised to act and undertake interventions as and when required. Response to service requests requiring investigation by officers, with resources focussed on cases with significant public health risks - G Page 177
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Joint Health Protection Plan 25-27 v1.0 Page | 36 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Joint protocol to be devised to manage vulnerable individuals displaying hoarding behaviour or whose lifestyle behaviour affects others. Hoarding cases investigated following guidance but Joint protocol not progressed Hoarding cases investigated following guidance but Joint protocol not progressed Joint protocol not progressed A Minimise the risk to the public from Lyme Disease Assist with ongoing research and reviews. Continue to raise public awareness. Review and develop websites/links to provide suitable information. Information on Ticks and Lyme disease promoted. Information on Ticks and Lyme disease promoted. G Reducing the impact of tobacco, alcohol and other harmful substances on public health Continued regulation of the smoking ban in enclosed and public places including NHS premises. Ongoing arrangements in place with NHS for them to manage their premises - no proactive enforcement from Council regarding smoking on NHS premises Smoke free premises – workplaces and public areas. Six complaints investigated relating specifically to cigarette smoking, either inside a workplace, outside a workplace or at premises entrance to premises e.g. doorway. Ongoing arrangements in place with NHS for them to manage their premises - G Continued work with licensed trade in respect of responsible drinking and minimum pricing. Part of the annual programme of inspections throughout the area completed Licencing Standards. This is completed either virtually, through a self- assessment or a physical visit. During this, premises are educated, encouraged and inspected to ensure compliance with the mentioned responsible drinking and minimum pricing requirements. Part of the annual programme of inspections throughout the area is completed by Licencing Standards. - G Page 178
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Joint Health Protection Plan 25-27 v1.0 Page | 37 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status Continue regulatory work on age- related sales activity of cigarettes and other products. Promotional campaign targeted at reducing the under-age sale of tobacco and vaping products to children and young adults. Trading Standards participate in the Enhanced Tobacco Sales Enforcement Programme (ETSP). This involves taking test purchases of tobacco and NVPs (vapes) in 10% of registered premises in Argyll and Bute. Make advice visits to 20% of registered premises in Argyll and Bute. TS active in under- age sales work and new single vape legislation TS active in under-age sales work and new single vape legislation and committed to meeting all targets in the ETSEP programme - G Joint working with the police relating to the sale of Novel Psychoactive Substances (NPS). NPS enforcement is a Police matter – regulation changes more enforced by Police Scotland. - - G Continue to review and consider possible health issues related to e- cigarettes. G Strong and Safe Communities To investigate and implement effective controls to minimise the spread of suspected and confirmed cases of communicable and notifiable diseases in the community. 332 recorded ‘infectious diseases’ notifications, each investigated and assessed by Environmental Health staff, with the relevant interventions then taken. Cases investigated and assessed by Environmental Health team, with the relevant interventions then taken. Enhanced performance management in place with respect to the monitoring of key performance indicators relating to the management of cases of notifiable infections. G The protection of the vulnerable in communities from the impact of cold calling and rogue traders. Argyll and Bute Council webpage “Council issues rogue traders warning” issued in April 2024 following “reports of rogue traders operating in Trading Standards active campaigns on rogue traders and scammers. - G Page 179
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Joint Health Protection Plan 25-27 v1.0 Page | 38 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status and around Oban and Dalmally”. Use of Trading Standards Facebook page for spreading the word about local issues or concerns which have been raised to the service. Install “TrueCall” blockers in vulnerable persons properties. Provide stickers which can be located on the front window / door to dissuade visitors / cold callers. Radon protection Ensure that the public in radon affected areas are provided with adequate information relating to the risks of radon and the mitigation measures which can be taken to reduce the risk Use of third-party monitoring by public encouraged where enquiries made Advice available to public on radon risks - G Raising awareness of radon monitoring responsibilities to employers and landlords. PWS assessed and where appropriate monitored with respect of Radon in drinking water PWS assessed and where appropriate monitored with respect of Radon in drinking water - G Produce a Radon Strategy for ABC to include council owned property and rented property. Radon strategy in place for Council properties. Radon strategy in place for Council properties. - G Ensure Radon awareness through development management. Radon mitigation practices considered as part of Building Warrant approval Radon mitigation practices considered as part of Building Warrant approval - G Education and advice programme Raising awareness of the Outdoor Code and communicable disease and controls through improved public information. Argyll and Bute Council webpage “Ticks and Lyme Disease”. webpage ‘Outdoor access rights and responsibilities’ to provide Advice available The website has been updated to reflect current circumstances. G Page 180
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Joint Health Protection Plan 25-27 v1.0 Page | 39 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status information to residents and visitors on how to “enjoy the countryside responsibly”. Development and review of existing information leaflets and improvements to website. Delivered through social media and websites Delivered through social media and websites Delivered through social media and websites G Where possible, consider and coordinate seasonal promotions and awareness raising campaigns e.g. a summer campaign highlighting the risks of ticks and barbecues. Argyll and Bute Council webpage provides guidance notes for the public and businesses in relation to the control of Legionella and the safe use of Spa Pools. Further guidance covers the safe use of Scandinavian hot tubs and outdoor baths. Argyll & Bute Council webpage also provides Legionella risk assessment template for landlords and spa pool self- assessment form. Argyll & Bute Council guidance on Non-Surgical Cosmetic Procedures published August 2025. Limited work undertaken using social media. The development of a calendar of communications has been carried forward into the next plan. A Increase awareness of health protection issues with local businesses through use of alternative enforcement plans. Major issues are addressed through national campaigns and specific local campaigns (e.g slushies, blue-green algae, etc) Major issues are addressed through national campaigns and specific local campaigns (e.g slushies, blue-green algae, etc) Major issues are addressed through national campaigns and specific local campaigns (e.g slushies, blue-green algae, etc) G Investigation of suspected and confirmed cases of communicable disease and implementation of All cases of ID reviewed and investigated by EH staff with follow up actions taken as All cases of ID reviewed and investigated by EH staff with follow up actions taken as required. Timely investigation and management of cases of communicable disease. G Page 181
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Joint Health Protection Plan 25-27 v1.0 Page | 40 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status appropriate controls to prevent further spread. required. Monitoring of performance in place. Monitoring of performance in place. Monitoring trends by enhanced surveillance and reporting. Use of Uniform ID module enables monitoring of trends Case management system Civica APP used to monitor trends Enhanced surveillance in place with new performance management processes in place. G Implement the national microbiology strategy locally and ensure appropriate access to testing in the public analyst labs. Actioned by Local Authority analytical services Actioned by Local Authority analytical services - G Ensure public health actions are taken to minimise risks from zoonotic infections reported by Scottish Veterinary Service (SVS). public health actions taken to minimise risks from zoonotic infections public health actions taken to minimise risks from zoonotic infections public health actions taken to minimise risks from zoonotic infections G Food safety priorities To undertake the duties as statutory Food Authority in protecting food safety in the food industry, and deliver the Councils’ Food Safety Law Enforcement Work plan. Mainstreamed and targeted based on available resource. Priority given to approved premises sector and higher risk premises Mainstreamed and targeted based on available resource. Priority given to approved premises sector and higher risk premises - G Work with other agencies to reduce the impact of illegal shellfish harvesting and distribution. On-going liaison with FSS Food Crime Unit On-going liaison with FSS Food Crime Unit - G Health and safety at work initiatives To complete the Councils’ Health and Safety at Work Law Enforcement Plan. Planned work interruptions ongoing due to 3 current fatality investigations. Investigation findings inform local priority initiatives for care/nursing homes and for swimming pools. Intelligence Ongoing work in response to accidents and fatalities. - G Page 182
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Joint Health Protection Plan 25-27 v1.0 Page | 41 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status and service requests also determine potential health and safety initiatives. Horizon Scanning and Emerging Infections Be aware of new and emerging infections and plan how to minimise their impact locally e.g. Mpox Liaised with NHS Highland Liaised with NHS Highland Preparedness work undertaken in relation to mpox and HCID more generally in addition to the re-emergence of measles. G Minimise the adverse impact of climate change Work together to mitigate the effects of climate change. Water Scarcity support arrangements in place for domestic properties on private water supplies Reactive response to incidents relating to weather, storms, landslides. Water Scarcity support arrangements in place for domestic properties on private water supplies Alert shared in relation to the risk of vector-borne diseases. Reactive response to incidents such as wildfires along with partner agencies. G Animal health and zoonoses Respond to current and emerging diseases such as the risks from avian influenza. Ongoing reactive response to emergent infections such as the increased incidence of avian influenza seen in 2023. Reviewed preparedness and plans to respond to avian influenza case(s) Ongoing engagement with poultry keepers through Council website. Promotion of Scottish Kept Bird Register to enable direct information provision as appropriate. Ongoing reactive response to emergent infections such as the increased incidence of avian influenza Ongoing reactive response to emergent infections such as the increased incidence of avian influenza seen in 2023. G Deal with the illegal import of animals. Any cases reported are investigated Any cases reported are investigated - G Carry out animal health and welfare enforcement activities in accordance with Framework Agreements. Animal Health and Welfare Framework document in place and agreed by Council. Focus of operational enforcement Animal Health and Welfare Framework document in place and agreed by Council - G Page 183
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Joint Health Protection Plan 25-27 v1.0 Page | 42 Outcome Work plan Argyll & Bute Council actions/comments Highland Council actions/comments NHS Highland actions/comments RAG Status work on livestock markets and high-risk premises, service complaints and joint working with Animal Health and Plant Agency and other partners Improve preparedness to deal with animal health disease outbreaks. Revised and implemented that specific disease control plans developed by the West of Scotland Regional Residence Groups Team engages with local and national animal health forums - G Workforce planning and resilience Training and support in incident management and response including STAC training. STAC training undertaken through UKHSA by new officers to enhance resilience across the service STAC training undertaken STAC training undertaken through UKHSA. G Workforce planning and resilience Service redesign undertaken and implemented. Resourcing issues are being addressed and new “career pathway” posts created due to EHO shortage across Scotland. Appointment of Trainee Graduate Food Safety Officer. Workforce planning ongoing to encourage career development. Redesign underway in 2025 A Water safety plans Develop water safety plans. Delayed due to resourcing – carry forward to 2025-27 plan Delayed due to resourcing – carry forward A Review of boat hirers arrangements. Delayed due to resourcing – carry forward to 2025-27 plan Delayed due to resourcing – carry forward A Coordinated approach to public health Actively participate in the national Scottish Health Protection Network and associated governance groups to promote a coordinated approach to protecting public health and developing new guidance and systems. Continued involvement in the SHPN topic groups and guidance development groups. Participation in Investigation of elevated levels of lead in drinking water guidance, due to be published October 2025 Senior EHOs actively involved in national groups Continued involvement in the SHPN topic groups and guidance development groups. G Page 184
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Joint Health Protection Plan 25-27 v1.0 Page | 44 3.2 Review of Standard Operating Procedures, Protocols and Plans NHS Highland and its two local authorities have numerous standard operating procedures (SOPs) and policies. These concern a variety of health protection issues including food safety. Each policy held by NHS Highland has a scheduled date of review. However, the competing priorities posed by the pandemic has meant that these had not been updated in accordance with planned timescales. This work continues to be prioritised as part of the remobilisation of the HPT and both local authorities. It is recognised that the updates to national guidance were also impacted by the pandemic and that local guidance will be updated in accordance with national updates. The Environmental Health Liaison Group provides an opportunity for members to highlight policies that may require revision in light of new evidence or legislation and to discuss issues of common interest. This is being reconvened along with the national drinking water meeting organised by Scottish Water. A survey is planned to best understand the needs of stakeholders and partner agencies to support development. Page 186
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Joint Health Protection Plan 25-27 v1.0 Page | 45 Section 4: Appendices 4.1 Appendix 1: List of joint NHS/Council Plans There are an increasing number of national plans for managing the public health management of infectious diseases and environmental hazards. Some key examples are: • Management of Public Health Incidents: Guidance on the Roles and Responsibilities of NHS led Incident Management Teams. • Scottish Waterborne Hazard Plan In addition to national plans sometimes there is a requirement to have, or added value in having, a specific joint local plan. Some key examples are listed below: Title 1. Investigation of Enteric disease protocol 2. Protocol for failures following scheduled statutory sampling of Private Water Supplies 3. Protocol for failures involving lead in water supplies 4. Blue-Green Algae (Cyanobacteria) in Inland and Inshore Waters: Assessment and Minimisation of Risks to Public Health. Monitoring and action plan for NHS Highland Board area. 5. Protocol for the investigation and management of viral outbreaks in the tourist and leisure Industry 6. Protocol for the investigation and management of viral outbreaks in care homes 7. Procedure for cases of illness in vessels arriving at ports/harbours in Highland & Argyll & Bute 8. Procedure for cases of illness in aircraft arriving at Inverness airport Page 187
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Joint Health Protection Plan 25-27 v1.0 Page | 46 4.2 Appendix 2: Designated Competent Persons under the Public Health etc. (Scotland) Act 2008 NHS Highland Dr Jenny Wares Consultant in Public Health Medicine (Health Protection) Dr Rob Henderson Consultant in Public Health Medicine Dr Nicola Schinaia Consultant in Public Health Medicine Dr Stephen Bridgman Consultant in Public Health Medicine Ms Lynda Davidson Senior Health Protection Nurse Ms Sandra Dekker Health Protection Nurse Ms Phyllis Smith Health Protection Nurse Highland Council Environmental health Lead Local Authority competent person: Alan Yates (Strategic Lead - Environmental Health & Bereavement Services) Depute Local Authority competent persons: Area EH Managers - Daniel Hopwood, Gregor MacCormick Senior EHOs - Patricia Sheldon, John Murray, Barry Cumming Competent persons Professional staff are authorised by the Strategic Lead - Environmental Health & Bereavement Services according to competency and experience. At the time of developing the plan, those EHOs are: Alana Steven, Philip Dent, Robert Murdoch, Zoe Skinner, Robin Fraser, Michael Hayes, Eleanor Hood, Sharon Stitt, Beatrice Aitken, Chris Ratter, Fiona Yates, Coila Hunter, Tanya Grosle, Eliza Subotovic Argyll & Bute Council Environmental health Lead Local Authority competent person: Alan Morrison, Senior Manager- Regulatory Services and Building Standards Depute Local Authority competent persons: Jacqui Middleton, Environmental Health Manager (West) Depute Local Authority competent persons: Mary Watt, Environmental Health Manager (East) Depute Local Authority competent persons: Mark Parry, Principal EHO (Public Health) Competent persons Professional staff are authorised by the Senior Manager - Regulatory Services and Building Standards Manager according to competency and experience. At the time of developing the plan, those EHO’s are: Page 188
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Joint Health Protection Plan 25-27 v1.0 Page | 47 Pamela Fraser, Cameron McAuley, Richard Gorman, Anthony Carson, Martin MacNiven, Nicole Hamilton, Jo Rains, Sue Stefek, Pauline Varley, Conor Brolly, and Andy MacLeod Page 189
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Joint Health Protection Plan (JHPP) Page | 48 4.3 Appendix 3: Supporting information 4.3.1 Health Protection Health protection is a specialist function within public health responsible for the investigation and management of communicable diseases and environmental hazards in order to protect population health. The health protection function is a key statutory responsibility for NHS Highland Health Board and acts to: • advise NHS Highland and its partners on health protection policies and programmes; • deliver services and supports the NHS and other agencies to protect people from communicable diseases, poisons, chemical and radiological hazards; • respond to new threats to public health; • and provide a rapid response to health protection incidents and outbreaks. NHS boards are accountable to the Scottish Government for protecting and improving the health of people living within their geographic areas. The Public Health (Scotland) Act 2008 provides clarity over the roles and responsibilities of NHS boards and Local Authorities (LAs) and provides extensive powers to protect public health. In general, NHS boards are responsible for people and LAs are responsible for premises. NHS boards and LAs have a duty to co-operate in exercising their functions under the Act, and to plan together to protect public health in their area as detailed within this JHPP. Environmental Health is the branch of Public Health that is concerned with all aspects of the natural and built environment that may affect human health. This remit is delivered within local authorities. The Environmental Health Service has a lead role in Health Protection through its regulatory core functions of Food Safety, Health and Safety at Work, Communicable Disease control, Public and Private Water Supplies, Monitoring bathing water quality, Contaminated Land, Air Quality, Noise control, Nuisance abatement, Smoking Enforcement, and prevention and control of Zoonotic diseases. The Trading Standards Service performs the Council’s Consumer protection function, which includes tobacco controls; product and consumer safety; licensing of persons, explosive and petroleum; feeding stuffs and fertilisers; age related sales and weights and measures. Page 190
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Joint Health Protection Plan (JHPP) Page | 49 4.3.2. Overview of NHS Highland and its Local Authority partners The NHS Highland board area, encompassing the two local authorities of Highland Council and Argyll and Bute Council, encompasses a vast and diverse area as detailed in the maps below. NHS Highland Area Map Argyll and Bute Council Area Map Highland Council Area Map The resident population is estimated to be 324,980 according to the latest population estimates.8 The population is ageing, this profile is increased by the Page 191
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Joint Health Protection Plan (JHPP) Page | 50 large number of young people leaving to continue education or seek employment in other urban settlements. The territorial area covers 32,560 km² which represents approximately 42% of the Scottish land surface. It extends across the most northerly and westerly fringes of the Scottish mainland and includes 36 inhabited islands. A large proportion of the population lives in remote rural towns and settlements. Transport infrastructure across much of the Highlands and Argyll and Bute consists of single road or rail networks. Island communities are reliant on ferries with few inter island connections. A large number of tourists visit the area throughout the year pursuing a variety of activities. This influx, particularly to remote and rural areas, increases demands on both health and local authority services. In order to facilitate trade and tourism, the area contains several air and sea ports providing local and international connections. 4.3.3 Resources and Operational Arrangements for Health Protection The human resources available for delivering health protection services are outlined in the table below. As detailed earlier in the plan, there has been an expansion as a result of the COVID-19 pandemic. Table 3: NHS Highland Health Protection Team Job Title Role and Responsibility WTE Director of Public Health Strategic and Operational Lead for Public Health activities in NHS Highland. 1 Consultant in Public Health Medicine (Health Protection) Provide leadership and strategic oversight for health protection development and implementation in NHS Highland. To co-ordinate the provision of an effective service for the control of communicable diseases and environmental health hazards on a 24/7 basis. 1 Health Protection Nurse Specialists Coordinate, lead and deliver activities surrounding the prevention, investigation and control of communicable diseases. 6.1 TB Liaison Nurse Coordinate the contact tracing for TB cases/contacts 0.4 Public Health Surveillance Officer Responsible for disease surveillance records and reports. 0.2 Administration and secretarial support Provision of administrative and secretarial support. 3 Page 192
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Joint Health Protection Plan (JHPP) Page | 51 Table 4: Argyll and Bute Council Job Title Role and Responsibility WTE Senior Manager- Regulatory Services and Building Standard Strategic and operational management of environmental health, animal health, short-term let and building standards Delivery of effective health protection interventions. Lead and support the development of staff. Effective management of resources. Council’s Head of Food Safety and Lead competent Public Health Officer. 1 Environmental Health Managers Management and delivery of the environmental health service within a geographical area of Argyll and Bute – east and west regions 2 Principal Environmental Health Officer (Food Control and Service Support) Provide specialist food safety advice and expertise within Argyll and Bute Council. Provides specific advice and supports the development of protocols, service plans and ensure that they are in line with current legislation. The inspection of high risk and EC approved food premises. 1 Principal Environmental Health Officer (Health and Safety and Service Support) Provide specialist health and safety advice and expertise within Argyll and Bute Council. Provides specific advice and supports the development of protocols, service plans and ensure that they are in line with current legislation. 1 Principal Environmental Health Officer (Public Health and Housing) Provide specialist public health advice and expertise within Argyll and Bute Council. Provides specific advice and supports the development of protocols, service plans relating to private water supply regulation, private landlord registration including houses of multiple occupation and public health. 1 Environmental Health Officers Full range of environmental health duties including public health, food safety, environmental protection and health and safety. 9 (3 vacant) Environmental Protection Officer Carrying out the Council’s statutory duty to identify contaminated land and local air quality. To deal with historic contamination under the planning process and by programmed inspection; to carry out risk assessments in accordance with legislation, statutory guidance and the Council’s published Strategy. 1 Page 193
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Joint Health Protection Plan (JHPP) Page | 52 Regulatory Services Officers (EH) To undertake a specific range of environmental health duties principally in food safety. 2 Regulatory Services Officers (PWS) To undertake specific duties relating to private water supply risk assessment and PWS grants 4 (0.6 FTE vacancy) Graduate Trainee Food Safety Officer To support food safety enforcement activity and undertake training/developmenet program to attain Higher Certificate in Food Control 1 Technical assistants/ Sampling Officers To support the environmental health service and undertake environmental sampling and monitoring programmes. 5.2 Senior Animal Health and Welfare To supervise the delivery of animal health and welfare service. To undertake programmed visits relating to animal health and welfare and primary food production. Investigate all cases of notifiable animal disease including zoonotic diseases. 0.6 Animal Health and Welfare Officer To undertake programmed visits relating to animal health, welfare and primary food production. Investigate all cases of notifiable animal disease including zoonotic disease 0.8 Trainee Animal Health and Welfare Officer Undertake work under supervision and complete training program. Career development post from Trainee to Authorised Officer to AHW Officer 0.6 Short-term let Licensing lead Delivery the operational work associated with the short- term let licensing scheme 1 Short-term let licensing team Enforcement and administrative staff delivering STL scheme 6 Private landlord registration team Deliver private landlord registration scheme in Argyll and Bute 2 Civil Contingencies Manager Ensuring Argyll & Bute Council is prepared for a major incident. 1 Civil Contingencies Officer Ensuring Argyll & Bute Council is prepared for a major incident. 1 Liquor Licensing Officers Focused on compliance, mediation and support relating to Liquor Licensing (Scotland) Act 2 Trading Standards Manager Manage, co-ordinate, lead and support activities surrounding Trading Standards. Develop protocols, service plans in line with current legislation. 1 Page 194
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Joint Health Protection Plan (JHPP) Page | 53 Trading Standards Officers and Regulatory Services Officers Carry out Trading Standards interventions in accordance with current plans, protocols and legislation 4 Table 5: Highland Council Job Title Role and Responsibility FTE Strategic Lead - Environmental Health & Bereavement Services Strategic and Operational Lead for Environmental Health and Public Health activities in Highland Council. 1 Area Environmental Health Mangers Strategic and Operational managers for Environmental Health 2 Senior EHOs Operational Lead in respective areas for Environmental Health and Public Health activities. 8 Environmental Health Officers Carry out Environmental Health and Public Health interventions and inspections in accordance with current plans, protocols and legislation. 17 (inc. 2 trainee posts) Environmental Health Technical Officers To undertake a specific range of environmental health duties principally in food safety and Health & Safety, pollution, licensing and housing. 20 Technical Assistants/ Sampling Officers To support the environmental health service and undertake water sampling and monitoring programmes. 6 Assistant Community Works Officer To support the environmental health service and undertake dog control, litter, fly-tipping, pest control 8 Scientific Officer (Contaminated Land) Carrying out the Council’s statutory duty to identify contaminated land. 1.91 Information Technician & system administrator Maintenance of the Council’s contaminated land information records & IT functions. 2 Animal Health & Welfare Officer Carry out Council’s statutory duty in relation to Animal Health and Welfare. 3 Trading Standards Manager Strategic and Operational Lead for Trading Standards. 1 Trading Standards Team Leader Coordinate, lead and support activities surrounding Trading Standards. 1 Page 195
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Joint Health Protection Plan (JHPP) Page | 54 Trading Standards Officers, Assistant Trading Standards Officers, Senior Enforcement Officers & Enforcement Officers Carry out Trading Standards interventions in accordance with current plans, protocols and legislation. 12 Liquor Licensing Standards Officers Carry out work with the licensed trade in respect of responsible drinking and minimum pricing. 2 4.3.4 Laboratory Services Arrangements to access laboratory facilities vary across the two local authorities. Argyll and Bute Coucnil have a Service Levels Agreement in place with Glasgow Scientific Services for the provision of the analytical servuces (to UKAS accreditation standards) together with the statutory appointments of Public Analyst, Food and Agricultural Examiner. Highland use Edinburgh Public Analyst and Scottish Water. The HPT utilise NHS clinical laboratories. 4.3.5 Emergency Planning and Service Continuity Resilience within NHS Highland is led by the Resilience Team (Head of Resilience and a Resilience Advisor). They provide specialist support and expertise and maintain operational links with multi-agency partners. Governance for this function is through the NHS Highland Resilience Committee and this group support the development of incident response and continuity plans across the Board. Highland Council and NHS Highland are members of the North Regional Resilience Partnership. Argyll & Bute Council and NHS Highland are members of the West Regional Resilience Partnership. In addition, there is the Highland & Islands Local Resilience Partnership and various locality groups as well. Argyll and Bute has its own Local Resilience Group with partner agencies. 4.3.6 Inter-organisational collaboration An updated approach to the feedback on disease surveillance collected as part of routine and statutory monitoring is being explored. Following the pandemic, meetings are held on a two-weekly basis between environmental health and health protection to discuss shared issues. In addition, the Environmental Health Liaison Group is being re-convened and will meet twice Page 196
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Joint Health Protection Plan (JHPP) Page | 55 per year. This will provide an opportunity to share key issues for which wider partnership working would be beneficial and to evaluate the management of significant incidents. Lessons learnt can be shared and disseminated within each partner agency. Following a significant incident, debriefing is organised routinely for the involved agencies. This provides an opportunity for those involved operationally and strategically to evaluate the management of the incident and provides a forum for critical reflection. A final incident report should be produced within six weeks of the debrief. Table 6: Inter-organisational collaboration Meeting / Group Membership Frequency Environmental Health Liaison Group NHSH, ABC, HC, Scottish Water, SEPA, Animal Health, SRUC, FSA, PHS 6 monthly Scottish Water Liaison Group Scottish Water, NHSH ABC, HC, DWQR 6 monthly 4.3.7 Mutual Aid Due to the vast geography of NHS Highland, it has been necessary to develop arrangements with NHS Greater Glasgow and Clyde in relation to the initial response to major incidents occurring within Argyll and Bute. In particular, there are specific arrangements written into the HM Naval Base Clyde Off-Site Contingency Plan which is designed to cover radiation emergencies at HM Naval Base Clyde. While NHS Highland retains overall responsibility for the NHS response, they would be assisted, particularly in the initial stages, by personnel from NHS Greater Glasgow and Clyde (NHS GGC), with staff from both boards being deployed to manage the incident from the Clyde Off-Site Centre. Additionally, depending on the extent and volume of casualties, designated receiving hospitals would be nominated within NHS GGC for the reception of casualties. Across the North of Scotland Public Health Network all participating public health departments have signed a mutual aid agreement which states that each Board will assist any of the others which has pressures it cannot meet on its own e.g. a large outbreak or incident. There is also an informal mutual local authority support arrangement in place with neighbouring authorities. 4.3.8 Out-of-hours arrangements NHS Highland Page 197
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Joint Health Protection Plan (JHPP) Page | 56 A senior member of public health staff is available 24 hours a day 7 days a week. Outside of office hours, this service is provided by public health consultants, health protection nurses and public health specialists, as well as training grade specialty registrars. The service can be accessed through the Raigmore hospital switchboard on 01463 704000. Raigmore laboratory provides a microbiology service out of hours. Urgent sample requests can be performed for some diseases following discussion with the on call microbiology team. National Reference laboratories will also perform analysis of urgent specimens following discussion of their appropriateness. Highland Council No on-call service is provided by the Environmental Health, however there are out-of-hours arrangements in place to access the service in case of emergency. This can be accessed through the following number: 01349 886690. Arrangements are in place to access public analyst or other appropriate laboratory services out with normal hours. Argyll and Bute Council No on-call service is provided by the Council, however there are out-of-hours arrangements in place to access the service in case of emergency. This can be done through the Regulatory Services Manager or the Civil Contingencies Manager through the following number: 01436 658988. Similar arrangements are in place to access laboratory services out with normal hours. 4.3.9 Maintenance of Competencies for Health Protection Staff NHS Highland NHS Highland staff undergo an annual appraisal to ensure their knowledge and skills remain up to date. The health protection team run regular update sessions for on call colleagues out with the HPT. Staff are encouraged to identify their own learning needs and attend external conferences and meetings as part of continuing professional development (CPD) activities. Nursing staff meet the requirements of the Knowledge and Skills Framework and the revalidation requirements of The Code (NMC). Highland Council Page 198
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Joint Health Protection Plan (JHPP) Page | 57 Highland Council has a corporate performance and development review process. Managers review staff training at regular intervals and as part of the employee review and development process. Argyll and Bute Council Argyll and Bute Council has a corporate performance and development review process with its entire staff. Appraisals are carried out on an annual basis. Details of this are held centrally on a register which managers review at regular intervals and as part of the employee appraisal process. The individual learning needs of each member of staff can be identified and targeted through this mechanism. Within Regulatory Services, professional and technical officers are required to meet the continued development requirements in the Royal Environmental Health Institute of Scotland’s CPD scheme. 4.3.10 Public Feedback NHS Highland Information is provided to the public through the use of local media and the NHS Highland website along with targeted written information where required. NHS Highland Health Protection Team does not have any formal processes for obtaining feedback from the public. Argyll and Bute Council Customer and business surveys are regularly undertaken as part of the customer engagement strategy. Whilst not specific to health protection, these surveys provide useful information about the service provided and are used to inform improvements and developments. Recent surveys have indicated that on average 94% of customers are satisfied with the service provided to them. Highland Council Information is provided to the public through the use of local media and the Highland Council website along with written information where required. Feedback surveys are available to the public. Page 199
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Joint Health Protection Plan (JHPP) Page | 58 Page 200
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Joint Health Protection Plan (JHPP) Page | 59 References 1 Scottish Government. Guidance on Part 1 and Designation of Competent Persons Regulations. Scottish Government, 2012. 2 UKHSA. Measles. UKHSA. Available from URL: https://ukhsa- dashboard.data.gov.uk/vaccine-preventable-diseases/measles 3 Public Health Scotland. Measles – data and surveillance. PHS, 2025. Available from URL: https://publichealthscotland.scot/population-health/health-protection/infectious- diseases/measles/data-and-surveillance/disease-surveillance/ 4 Public Health Scotland. Immunisation and vaccine-preventable diseases quarterly report – January to March 2025 (Q1). PHS, 2025. Available from URL: https://publichealthscotland.scot/publications/immunisation-and-vaccine-preventable- diseases-quarterly-report/immunisation-and-vaccine-preventable-diseases-quarterly- report-january-to-march-2025-q1/main-points/ 5 Sniffer. Evidence for the third UK Climate Change Risk Assessment (CCRA3) – Summary for Scotland. UK Climate Risk, 2021 6 DWQR. Private Water Supplies Drinking Water Quality in Scotland 2023. DWQR, 2024. Available from URL: https://dwqr.scot/media/xpxnhhxz/private-water-supply- annual-report-2023.pdf 7 Scottish Government and COSLA. Public Health Priorities for Scotland. Scottish Government, 2018. 8 National Records of Scotland. Population estimates time series data. NRS. Available from URL: https://www.nrscotland.gov.uk/publications/population-estimates-time-series- data/ Page 201
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7 Appendix II: Infogram illustrating the role of environmental health in public health Page 202
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1 ARGYLL AND BUTE COUNCIL DEVELOPMENT AND ECONOMIC GROWTH PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE UPDATE ON RECENT TAYNUILT BESS APPEAL _________________________________________________________________________ OUR REFERENCE: 24/02083/PP DPEA REFERENCE: PPA-130-2094 CASE DETAIL: Installation of an energy storage facility including battery enclosures, transformers, substation, grid connection, infrastructure, earthworks, vehicular access, landscaping and associated works SITE ADDRESS: Land to the immediate west of Taynuilt Substation, Taynuilt APPLICANT: Downing Renewable Developments STATUS: Appeal Allowed by decision dated 14 November 2025 _______________________________________________________________________ 1. INTRODUCTION 1.1 Members may recall that determination of this application was initially deferred at PPSL to hold a pre-determination hearing before making a decision to approve or refuse the proposals. Officers had recommended that the application should be approved subject to conditions. Following this PPSL decision to hold a hearing, the applicant subsequently lodged an appeal against non-determination in advance of the proposed hearing date removing the determination of the application from the Planning Authority. This is an unusual occurrence but is within the rights of the applicant to do so. 1.2 This report summarises the decision made by the Reporter appointed by the DPEA 2. RECOMMENDATION 2.1 Members are asked to note the contents of the report. 3. REPORTERS CONCLUSIONS (Paragraph Numbers taken from Appeal Decision) The following excerpts have been taken from the Reporter’s conclusions: Preliminary Matters (Please note these paragraphs are not numbered in the appeal decision) “Whilst there have been criticisms of this decision being taken out of the hands of the council, the appellant has exercised a statutory right of appeal as the application had not been determined by the council within prescribed timescales. I noted requests for a hearing to be held to allow the community to express its views on this proposal. The purpose of a hearing would ordinarily be to explore contradictory or unclear written evidence. In this case I am satisfied that I have sufficient information on all matters, including those raised in representations from the local community together with my own observations during my site inspection, to be able to determine this appeal without the need for a hearing.” Page 203 Agenda Item 8
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2 Principle of Development “3. NPF4 policy 11 ‘Energy’ provides overarching support in principle for all forms of renewable, low-carbon and zero emissions technologies, and this explicitly extends to battery energy storage as established by part a)(iii) of the policy. This in-principle support is framed more widely by policy 1 ‘Tackling the climate and nature crises’, which requires significant weight to be given to these matters in decision-making. 5. It is also beyond the scope of this appeal to explore whether locations, other than that proposed, may be more preferable for the development to be located. There is no policy basis for such an approach, and I must assess the proposal on its own merits, rather than undertake a comparative assessment of theoretical alternative sites. I have noted that the appellant has provided a site selection report which sets out why, in its view, the appeal site is preferable from an environmental and technical perspective. It is still the case that an unsuitable site would not become appropriate simply because of an absence of a better alternative in the area.” Landscape and Visual Effects “9. The site is well contained within the landscape, by virtue of rising land to the south, and trees and vegetation along the southern verge of the A85. Despite the development’s rather incongruous character in a rural setting, once beyond the immediate vicinity of the proposed development its effect on landscape character would rapidly diminish. The very limited wider visibility of the site, the fairly modest scale of the proposed development and its proximity to the existing substation combine to limit its effect on the character of the landscape in which it would be seen directly, or seen from indirectly. I am satisfied that the development’s overall impact on landscape features and character would be negligible on this basis. 10. The visual effects of the development would similarly be highly localised. There would be glimpsing and partial views of the development from the A85, which would be seen in the context of the neighbouring substation. It would not interrupt any longer range views available from the road. It would be sufficiently distant from Taynuilt to not have any bearing on the setting of the village and the visual amenity this provides.” Noise/Residential Amenity “17. In my judgement, the greatest potential for the proposed development to have adverse residential amenity effects would be as a result of noise. Noise is one of the various considerations identified by NPF4 policy 11(e) and LDP policy 30. A revised noise impact assessment (dated 31 March 2025) was submitted by the appellant to the council, which predicts that the highest noise levels would be at the nearest noise-sensitive receptors (which as identified above are Fairy Hill Croft and the consented dwelling on land at croft 4) but this would not exceed the representative background sound level. 18. The assessment inevitably applies a number of assumptions in making that prediction. Given the appellant has not to date specified the precise equipment manufacturers and models for example, it is conceivable that the noise emissions could differ, but the assessment is intended to present a realistic worst case scenario. The council’s environmental health officer has reviewed the assessment, and accepts its findings, including that internal noise levels set by BS8233: 2014 would not be exceeded at the nearest properties, whether windows are open or closed. I attach weight to this finding, but nevertheless, I consider that in order to provide an adequate safeguard against noise Page 204
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3 disturbance occurring, a condition should be imposed (which I note the council has also recommended) to require the development to not exceed the noise levels predicted in the appellant’s revised noise impact assessment. Subject to this requirement, there is no reason to conclude that noise would result in a loss of residential amenity at any property. 19. In conclusion, I am satisfied that all existing and consented dwellings in the general vicinity of the proposed development would not be subject to a significant loss of residential amenity, with most properties being entirely unaffected. In this regard the proposal does not give rise to any conflict with the relevant provisions of NPF4 policy 11 and LDP policy 30.” Fire Risk “21. It is not the role of the planning system to manage fire risk, and this is addressed by other regulatory regimes. It is however capable of being a material consideration insofar as where there might be spatial and land use implications for managing any residual risk. 22. Whilst the possibility of a BES fire cannot be ruled out, it also cannot be described as likely. In my view it is reasonable to assert from the policy support provided for BES by NPF4 policy 11 (which is provided without any reference to locational principles relating to fire risk) that there is no reason to anticipate or expect a fire to occur. There is nothing before me which would distinguish a BES from many other less novel types of development in terms of residual fire risk. 23. There would be particular characteristics of a BES fire, should it occur, giving rise to specific fire containment and suppression methods. This has led to the National Fire Chiefs Council publishing best practice guidance for fire and rescue services, which also contains design principles that have some limited relevance to the planning process. This proposed development would provide two separate access points to the facility, together with a perimeter road. The red line development boundary is drawn sufficiently widely to provide flexibility over the final alignment of the access roads, so that at least one access could be used in the event of a fire regardless of wind direction. A water tank is proposed, to provide an immediate adequate on-site supply. Sufficient separation between the BES units and proposed landscaping/vegetation screening could be ensured as part of a scheme to be required by planning condition, thereby minimising any risk of a fire spreading.” “28. Concern has been raised that water used for fire suppression would contain pollutants, with run-off potentially entering the River Awe. The proposal is accompanied by a surface water drainage strategy which takes this into account and outlines how this risk would be mitigated. Whilst it is incumbent on the appellant to manage the residual direct and indirect risk of a fire including the potential for pollution, as already noted my assessment must confine itself to the operational nature of the development and land use implications of this. It is not relevant to a development management decision to have regard to all possible impacts of a fire when the likelihood of such an event is low. 29. All told, whilst I acknowledge the concerns expressed by some of the community relating to the possibility of a battery fire, I am satisfied that, from a land use perspective, this matter is not a constraint to development for the reasons outlined above. Detailed matters of access, and buffers between battery units and vegetation can be secured by condition, but the residual possibility of a fire occurring, or hypothetical broader implications of such an incident, are not matters for the planning system to regulate. This is further reinforced by SEPA’s position that it only provides site-specific advice on the implications of accidents if it falls within the Control of Major Accident Hazard (COMAH) regulatory regime, which BES developments do not. I do not consider many of the provisions of NPF4 policy 23 (‘Health and safety’) to be engaged, as a BES proposal is not ordinarily deemed to involve hazardous substances, nor is it recognised as a major accident hazard. Part (b) of Page 205
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4 NPF4 policy 4 ‘Natural places’ has been satisfied by an appropriate assessment having been carried out.” Biodiversity Net Gain “33. NPF4 policy 3 ‘Biodiversity’ includes criteria which apply to major development. The findings of the ecological appraisal submitted by the appellant indicates that there would be limited effects on protected species or their supporting habitats, and it recommends various good practice measures to mitigate the residual effects. On the basis of this evidence I consider that there would be limited scope for negative effects even without mitigation, so subject to conditions to require the suggested measures to be implemented, I am satisfied that the mitigation hierarchy has been followed. Part (iv) of the policy also requires significant biodiversity enhancements to be provided, in addition to mitigation. The ecological appraisal makes suggestions in this regard, and I consider there to be clear potential to approach proposed planting for the purposes of screening the development in a way that would also maximise its biodiversity benefits. The red line site boundary is sufficiently extensive to enable on-site significant biodiversity enhancement, but this is a matter which can appropriately be addressed by requiring a scheme to be submitted to and agreed by the council. Subject to this, the proposal would accord with NPF4 policy 3 overall.” Overall Conclusions “36. There is explicit policy support in principle for the proposed development, and the development plan is also instructive that significant weight is to be given both to the contribution it would make to greenhouse gas emissions reduction targets (achieved here by storing renewable energy until it is required) and the climate crisis more widely. 37. I acknowledge that there are widely held concerns and objections to the proposal from some of the local community, but these partly stem from safety concerns which extend beyond the scope of my assessment. Based on my foregoing reasoning I find the adverse effects of the development to be limited and highly localised. Some of these matters would be required to be subject to conditions, as would other considerations such as the need for archaeological investigations, and decommissioning plans. In the face of the policy presumption in favour of development and having assessed the site-specific characteristics and its suitability for the proposed development, I find there to be no conflict with the development plan in terms of applicable thematic or locational considerations, against which the in-principle support would need to be balanced.” “39. I therefore conclude, for the reasons set out above, that the proposed development accords overall with the relevant provisions of the development plan and that there are no material considerations which would still justify refusing to grant planning permission. I have considered all the other matters raised insofar as these are capable of being material considerations, but there are none which would lead me to alter my conclusions.” Full details of the case can be found at the following link: Scottish Government - DPEA - Case Details 4.0 IMPLICATIONS Policy: None. Financial: None. Legal: None Page 206
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5 HR: None Customer Service: None Risk: None Climate Change: None Fairer Scotland Duty: None Equalities: None Consumer Duty: None Island Communities: None Children’s Rights and Wellbeing: None Author: David Moore Date: 28.11.25 Fergus Murray Head of Development and Economic Growth Page 207
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ARGYLL AND BUTE COUNCIL PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE DEVELOPMENT AND ECONOMIC GROWTH 17TH DECEMBER 2025 Local Development Plan 3 – Evidence Report Stage Engagement 1.0 EXECUTIVE SUMMARY 1.1 The purpose of this report is to notify PPSL Committee of the first stage of engagement for Local Development Plan 3 (LDP3), which Members may recall is significantly changed due to changes in the planning legislation. 1.2 The planning authority is required to prepare an Evidence Report to inform and justify the content of the next Local Development Plan (LDP3). The issues to be covered by the Evidence Report are also determined by legislation and are set out in the report. They are divided into 18 Topic Papers and cover a wide range of issues including: Housing, Transport, Infrastructure, Biodiversity, Economy, Flooding, and Play Space. 1.3 The Evidence Report will be informed by the views of stakeholders including key agencies, children and young people, and the general public, to ensure collaborative and transparent evidence gathering. A variety of engagement methods are being employed including the Place Standard Tool. Over the coming months, draft Topic Papers will be placed online for public comment regarding their accuracy and sufficiency to develop LDP3. Once the engagement process has been completed and the Evidence Report finalised, this will be presented to Members at Full Council for approval prior to submission to Scottish Ministers for a Gatecheck, which essentially will seek to confirm that there is sufficient evidence presented to form the basis of preparation of LDP3.. 1.4 Recommendations It is recommended that PPSL: i) Note the contents of this report and the engagement process being undertaken to inform the LDP3 Evidence Report. Page 209 Agenda Item 9
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ARGYLL AND BUTE COUNCIL PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE DEVELOPMENT AND ECONOMIC GROWTH 17TH DECEMBER 2025 Local Development Plan 3 – Evidence Report Stage Engagement 2.0 INTRODUCTION 2.1 The planning authority is required to prepare an Evidence Report to inform and justify the content of the next Local Development Plan (LDP3). This will be collated around policy topics, and in addition to the 18 Topic Papers, will be supplemented by additional work including a Play Sufficiency Assessment. The Evidence Report is to be informed by the views of stakeholders including key agencies, children and young people, and the general public, to ensure collaborative and transparent evidence gathering. 3.0 RECOMMENDATIONS 3.1 Recommendations It is recommended that PPSL: i) Note the contents of this report and the engagement process being undertaken to inform the LDP3 Evidence Report. 4.0 DETAIL 4.1 The planning authority is required to prepare an Evidence Report to inform and justify the content of the next Local Development Plan (LDP3). 4.2 Section 15 (5) of the Town and Country Planning (Scotland) Act 1997 (as amended by the Planning (Scotland) Act 2019) (“the Act (as amended)”) sets out the matters which must be taken into account through the Evidence report, Page 210
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which will be collated around policy topics. To comply with this, 18 Topic Papers will be prepared and these are listed below: 1. Climate Change 2. Biodiversity, Woodland and Forestry, and Soils 3. Landscape, Rural Development, and Tourism 4. Historic Assets and Places 5. Vacant and Derelict Land 6. Energy (Renewables) 7. Transport 8. Local Living, and Design, Quality and Place 9. Housing 10. Infrastructure 11. Green and Blue Infrastructure 12. Play Space 13. Flood Risk and Water Management 14. Economy 15. Town Centres and Retail 16. Aquaculture 17. Minerals 18. Green Belt 4.3 Additionally, under section 16(D) of the Act (as amended), the planning authority must assess the sufficiency of play opportunities in its area for children in preparing the evidence report. The Town and Country Planning (Play Sufficiency Assessment) (Scotland) Regulations 2023 set out the form and content that is required of a Play Sufficiency Assessment (PSA) as well as the consultation requirements for this. 4.4 Section 16(B) of the Act (as amended) requires that, in preparing the evidence report the planning authority are to seek the views of, and have regard to any views expressed by: (a) the key agencies, (b) children and young people, in particular school pupils, youth councillors and youth parliament representatives, (c) such other persons as may be prescribed, and (d) the public at large 4.5 Additionally, for the PSA, The Town and Country Planning (Play Sufficiency Assessment) (Scotland) Regulations 2023 require that, in preparing the PSA, the planning authority must consult: (a) children, (b) parents and carers, (c) community councils within the planning authority’s area established under Part IV of the Local Government (Scotland) Act 1973(3), and such other community bodies or persons whom the planning authority consider should be consulted, and (d) the public Page 211
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4.6 Key agencies, as well as other relevant stakeholder groups, are being engaged with prior to public engagement on each Topic Paper. Additionally, the Topic Papers will be sent to the neighbouring planning authorities at the same time as these are each made available for public engagement. 4.7 In order to comply with section 16(B) of the Act (as amended), public engagement will be undertaken by publishing each Topic Paper online for a period of 6 weeks. A form will be made available for members of the public and community groups to complete to provide their views on whether the evidence is accurate and sufficient, to determine the implications for LDP3. It is anticipated that the 18 Topic Papers will be split into around 3 batches, with between 5 and 7 Topic Papers (and associated appendices) being online at one time, with the first set going online in early 2026. 4.8 Separately, to inform the Design, Quality and Place Topic paper, Place Standard Tool engagement is being used (as recommended in the LDP Guidance. This is a method that is suitable for children and adults alike, and which has been used by the council previously. In addition to public online engagement, Officers are working with schools to undertake targeted youth engagement. 4.9 In order to comply with section 16 (D) of the Act (as amended), as well as The Town and Country Planning (Play Sufficiency Assessment) (Scotland) Regulations 2023, two online surveys have been developed – one for children and a separate one for parents / carers and the wider public. 4.10 Following this engagement and subsequent finalisation of the Evidence Report, this will be presented to Members at a full Council Committee before being submitted to Scottish Ministers for Gatecheck, as required by Section 16 (B) (5) and (6) of the Act (as amended). 5.0 CONCLUSION 5.1 Engagement in the preparation of LDP3 is a vital component in the Town and Country Planning (Scotland) Act 1997 (as amended). The engagement process outlined herein will ensure collaborative and transparent evidence gathering to inform and justify the content of LDP3. 6.0 IMPLICATIONS 6.1 Policy – Local Development Plan 3 will replace Local Development Plan 2 (adopted 28th February 2024) in due course. Page 212
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6.2 Financial – The Evidence Report stage engagement is being undertaken in- house with no cost pressure. The costs for Gatecheck and Examination are outwith the Development Policy budget and are a cost pressure. Based on previous experience of the existing system these are likely to be in the order of £70-£100k. 30% of this cost would be anticipated in 2026/27 for the Gatecheck. 6.3 Legal – there is a statutory duty to engage during the Evidence Report stage of LDP preparation. 6.4 HR - None 6.5 Customer Service – This report sets out how customers can get involved in the early stage of the LDP3 process. The formal consultation period will be held following production of the Proposed Plan. 6.6 Risk - The preparation of LDP3 will run over 5 years and therefore there is an uncertainty regarding resource levels. Further reduction in resource levels would impact on delivery of LDP3 and could result in failure to meet legislative requirements and Scottish Government performance targets. 6.7 Climate Change - LDP3 will provide an up-to-date position in terms of land use development and climate change impacts against which to assess planning applications. A Strategic Environmental Assessment (SEA) will be carried out as part of the LDP3 process. 6.8 Fairer Scotland Duty - The engagement at Evidence Report stage (as well as subsequent stages) is being handled to encourage engagement with all. An Equalities Impact Assessment will be undertaken as part of the LDP3 process. 6.9 Equalities - protected characteristics. The engagement at Evidence Report stage (as well as subsequent stages) is being handled to encourage engagement with all. An Equalities Impact Assessment will be undertaken as part of the LDP3 process. 6.10 Consumer Duty - The engagement at Evidence Report stage (as well as subsequent stages) is being handled to encourage engagement with all. An Equalities Impact Assessment will be undertaken as part of the LDP3 process. 6.11 Island Communities - The engagement at Evidence Report stage (as well as subsequent stages) is being handled to encourage engagement with all. An Equalities Impact Assessment will be undertaken as part of the LDP3 process. 6.12 Children’s Rights and Wellbeing - LDP Preparation Guidance requires that Local Authorities make provision for inclusion of children and young people within the preparation of LDPs. Kirsty Flanagan, Executive Director with responsibility for Development and Economic Growth Page 213
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Policy Lead: Councillor Gordon Blair 28th November 2025 For further information contact: Kim de Buiteléir - kim.debuiteleir@argyll-bute.gov.uk APPENDICES None Page 214