Democracy Spraffa

Dawnfresh Farming Ltd: Replace Existing 10 X 70M Circumference Pens in 2 X 5 Grid with 6 X 120M Circumference Pens in 1 X 6 Grid, Including Increasing Biomass from 458.4 Tonnes to 700 Tonnes and Installation of Feed Barge: Port Na Mine Fish Farm (Etive 3), Inverawe, Taynuilt (Ref: 25/00093/Mff)

Argyll and Bute Council · 18 June 2025
Back to Planning, Protective Services and Licensing Committee — 18 June 2025 and its agenda

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Classification: OFFICIAL 
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: 25/00093/MFF
Planning
Hierarchy:
Local Application
Applicant: DawnFresh Farming Ltd
Proposal: Replace existing 10 x 70m circumference pens in 2 x 5 grid with 6 x
120m circumference pens in 1 x 6 grid, including increasing biomass
from 458.4 tonnes to 700 tonnes and installation of feed barge
Site Address:  Port Na Mine Fish Farm (Etive 3), Inverawe, Taynuilt, 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 10 x 70m circumference pens in 2 x 5 grid
arrangement to 6 x 120m circumference pens in a 1 x 6 mooring grid;
• Installation of pole mounted top nets;
• Installation of moorings;
• Installation of 200 tonne hybrid feed barge. 
(ii) Other specified operations
• Biomass increase from 458.4 tonnes to 700 tonnes.
• Navigational lighting in accordance with the requirements of the National
Lighthouse Board. 
(B) RECOMMENDATION: 
Having due regard to the Development Plan and all other material considerations, it is
recommended that planning permission be approved, subject to the conditions. 
(C) CONSULTATIONS:   
Marine Directorate of the Scottish Government (MDSG) (dated 13/3/2025):
In relation to benthic impacts, noted that the SEPA screening modelling and risk

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Classification: OFFICIAL
identification report demonstrates that a biomass of 700t can be supported on
the site while the transfer of biomass from Etive 2 site would result in no net
increase in biomass in the loch and therefore no water column impacts are
expected. The site falls within Disease Management Area 15b and the proposed
modification will not alter the current area Disease Management Area for this
site. 
The operation of the sites will be at an acceptable stocking density level of below
22kg/m3 and it should be made clear in any permission granted that only one
species is to be stocked on site at any one time. 
The predator mitigation plan states that a cone lift up system is used to collect
and retrieve mortalities from the net base daily – confirmation should be
provided that this remains relevant to the site or further information provided on
the proposed method and frequency of mortality removal. 
Historic sea lice levels were below SGMD reporting/increased monitoring levels
although it is noted there were periods of very high sea lice levels in September
2021 at Etive 6 and Etive 3. However, the Loch Etive sites have recently
changed from rainbow trout production to production of Atlantic salmon post-
smolts, in which the sites are stocked for short periods of 6-7 months and then
synchronously fallowed for at least 4 weeks to improve sea lice management.
The modelling provided suggests this stocking strategy would avoid the high lice
numbers observed during the second summer at sea. Generally, the reduction
in pen number from 10 to 6 is likely to result in increased efficiencies on site
when performing husbandry operations and sea lice monitoring procedures. 
The proposed contingency plan for dealing with an escape or suspected escape
event is satisfactory as is the information provided on equipment and strategies
to minimise predator interactions. The applicant should confirm the Predator
Mitigation Plan dated February 2024 is relevant to the modified site. The
applicant has provided self-attestation for the equipment proposed to be used
on site but should confirm that the attestation remains relevant to the
modifications proposed in March 2025. 
The Awe catchment that neighbours the site is known to have fisheries for sea
trout and evidence suggests that lice from fish farming can cause a risk to sea
trout. The applicant appears to be aware of the potential impacts on sea trout
and has indicated they intend to manage the site as part of the local FMA
(area M-36). They undertake to follow recommended industry practises
relating to sea lice control and containment. As sea trout are present in these
onshore waters all year round, strict control of sea lice should be practiced
throughout the year. 
From 2025 SEPA are expected to implement an adaptive approach to managing
interactions between sea lice from fish farms and sea trout, to be overseen by
a new national monitoring programme (although this has not yet been
implemented). As such, an Environmental Management Plan has not been
submitted for this proposal and therefore planning condition is recommended to
include a 6 month review period to require an EMP to be submitted and
approved by the local Planning Authority, should the national risk assessment
not be implemented.

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Classification: OFFICIAL
Officer comment: there is an existing EMP In place for Loch Etive (dated
5.12.23) which the applicant has confirmed remains appropriate for this site until
such time as the new Framework is implemented. 
Further information required by MDSG:
• Confirmation on mortality removal and disposal procedures
• Confirmation on use of cleaner fish species on site
• Confirmation that predator mitigation plan is relevant to modified site
• Confirmation that equipment attestation is relevant to modified site
• Slice consent clarification
• Predicted time to complete treatments with Deltamethrin 
Following the submission of further information by the applicant on 28.4.2025,
MDSG confirm on 22.5.2025 that the following matters have been satisfactorily
resolved:
• The applicant confirms that mortalities will continue to be removed at
least daily and mortalities incinerated or ensiled on site prior to uplift to
an approved facility by a licensed waste carrier.
• The applicant confirms that cleaner fish species, typically farmed ballan
wrasse and wild caught wrasse of mixed species, are proposed for use
on site. During Mowi’s operation of the sites with Atlantic salmon, wild
wrasse were found naturally occurring in a pen at Etive 3; indicating that
they were already present in the local environment. Following extensive
consultation by the applicant’s health and welfare department, it was
decided to stock pens with wrasse to increase available sea lice
management methods and have a preventative sea lice measure in
place throughout these short production cycles, which may reduce the
requirement for any reactive interventions resulting from increased sea
lice numbers on site. It is proposed that wrasse will move to the
ongrowing site at the end of their Etive production cycle. 
• The applicant has confirmed that although the dates on the predator
mitigation plan and equipment attestation are historical, these
documents are relevant to the proposed modifications, therefore it is
deemed satisfactory as far as can reasonably be foreseen.
• The applicant has confirmed that the quantity of SLICE would be
sufficient to treat the maximum biomass, if required. The applicant has
confirmed that the quantity of Deltamethrin would be sufficient to treat 3
pens per day; completing site treatment within 2 days. 
Argyll and District Salmon Fishery Board (dated 24/10/24):  
Our consultation response to the application is made in respect to the
importance of migratory fish populations in several rivers in Loch Etive including
the Rivers Awe, Etive, Kinglass and Nant which support important populations
of Atlantic salmon 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.

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Classification: OFFICIAL
Given the proximity of this and other farms in Loch Etive to rivers that support
wild salmon populations, the increase in risk of impactful interaction
(interbreeding) of escaped farmed fish on wild salmonoid populations is
significant. Therefore, Argyll DSFB 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. 
Argyll DSFB do not object to the increase in tonnage held at the site from 458.4
to 700 tonnes on the basis that the production of farm fish at the Etive 2 site is
ceased and the planning permission is rescinded. 
Officer comment: the ceasing of production at Etive 2 would be regulated
through the revocation of the CAR license by SEPA. In addition, a planning
condition is proposed to ensure the removal of all equipment from the Etive 2
site within 6 months of the CAR license being revoked. 
NatureScot (dated 11/4/2025): Proposal is located adjacent to Loch Etive
Woods SAC, designated for its woodland features and otter population.
NatureScot advise it is unlikely that the Proposal will have a significant effect on
the qualifying interests either directly or indirectly. An appropriate Assessment
is therefore not required. 
The proposal has no connectivity with the woodland qualifying interests of the
SAC and therefore no likely significant effect on this feature. Due to the ongoing
management of the site we do not believe significant disturbance of the otter
qualifying interest will occur as a result of the proposal. 
Standing advice and technical guidance provided in relation to Special
Protection Areas (SPA) with breeding Gannet interest and pole supported top
nets. 
Advise the site is within connectivity of the Priority Marine Feature (PMF)
burrowed mud which has a medium sensitivity for this feature to organic
enrichment and siltation and sets a sensitivity of ‘sensitive’ to synthetic
compounds (including pesticides). The proposal is therefore capable of affecting
the feature however, the proposal will not result in an overall net increase in
biomass in the Loch, as Etive 2 is to be relinquished (which also has connectivity
to burrowed mud). Burrowed mud is a widespread habitat in Loch Etive and any
loss or damage to this PMF habitat as a result of the proposal is unlikely to be
significant in the context of the Loch as a whole. 
The proposal is an established site within a Wild Salmonid Protection Zone.
Under the new sea lice regulatory framework, SEPA lead on sea lice and wild
salmonoid interactions. SEPA should ensure that the proposed change in
production will not increase sea lice risk. 
Historic Environment Scotland (dated 2/2/25): Consider that the proposals
have the potential to affect the following heritage assets: 
• SM2527 Dun Mor, motte 380m WNW of Balure Cottage (Scheduled
Monument)
• SM3773 Dun Leigh, dun 200m ENE of Balure (Scheduled Monument)
No comments to make on the proposals. This application should be determined
in accordance with national and local policy on development affecting the
historic environment, together with related policy guidance.

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Classification: OFFICIAL
Officer comment: please see Planning Policy Assessment for ‘The natural, built
and / or historic or archaeological sites and their settings’. 
SEPA (12//2025): No objection from a planning perspective but provide advice
on the need for authorisation under the Water Environment (Controlled
Activities) (Scotland) Regulations 2011 (CAR). Surveys have shown that the
area of impact from farm activity has remained within the immediate site vicinity.
NewDepomod modelling indicates the Environmental Quality Standards for
waste solids will be met using the proposed layout. The proposed offset in
biomass at Etive 3 by relinquishing the Etive 2 site would result in a net decrease
in biomass of 8.4 tonnes, meaning the nutrient enhancement index would not
change. 
None of the Priority Marine Features within the vicinity of the farm are
considered to be at risk from the proposal for issues within SEPA’s remit. This
is also applicable to the qualifying interests of the SAC. The site is located within
the Loch Etive Wild Salmonid Protection Zone. Sea lice screening has been
undertaken and has shown minimal effect on the exposure risk. 
Northern Lighthouse Board (dated 4/3/25): Consultation response includes
details of lighting and marking requirements. 
Officer comment: these requirements have been attached as informative notes. 
Royal Yachting Association (dated 19/3/25): RYA Scotland has no objection
to this application. 
Argyll and Bute Biodiversity Officer (dated 11/3/25): No comments. 
Argyll and Bute Area Roads Team (dated 24/4/25): No objections or
concerns. 
(D) HISTORY:   
14/02249/MFF Modification of existing fin fish farm site comprising 6 additional cages,
addition of feed barge and increase of cage sizes from 70 metre circumference to 80 metre
circumference and increase in extent of moorings. Port Na Mine Fish Farm (Etive
3) (WITHDRAWN 18.12.2014) 
16/01971/MFF Expansion of fin fish farm to comprise 10 x 80 metre cages and increase in
extent of moorings | Port Na Mine Fish Farm (Etive 3) Inverawe Taynuilt Argyll (PER
24.10.2016) 
18/01125/PP Use of land to accommodate the temporary storing of aquaculture equipment
for undertaking maintenance (retrospective) (PER 22.8.2018) 
18/01124/MFF Replacement of 10 x 80m circumference cages with 12 x 80m circumference
cages of an alternative design, installation of hopper feed system and biomass of 1545
tonnes | Airds Bay (Etive 4) (PER 22.8.2018) 
23/01830/SCREEN Etive 2 Screening Opinion for the removal of Condition 2 relative to
Audit and Review planning permission SFA/ABC/046 to allow the stocking of Atlantic
Salmon

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Classification: OFFICIAL 
23/01831/SCREEN Port Na Mine Fish Farm (Etive 3) Screening Opinion for the removal of
Condition 2 relative to planning permission reference 16/01971/MFF to allow the stocking
of Atlantic Salmon 
23/01445/MFF Etive 2, Application under Section 42 for the removal of Condition 2 relative
to Audit and Review planning permission SFA/ABC/046 to allow the stocking of Atlantic
Salmon 
23/01446/MFF Etive 2, Application under Section 42 for the removal of Condition 2 relative
to Audit and Review planning permission 16/01971/MFF to allow the stocking of Atlantic
Salmon 
23/01445/MFF Etive 2, Application under Section 42 for the removal of Condition 2 relative
to Audit and Review planning permission SFA/ABC/046 to allow the stocking of Atlantic
Salmon 
24/01644/SCREEN Port Na Mine Fish Farm (Etive 3) Screening opinion for the replacement
of existing 70m circumference pens with six 120m circumference pens, install low profile
feed barge and transfer consented biomass from Etive 2 
(E) PUBLICITY:   
ADVERT TYPE:
Regulation 20 Advert Local Application
EXPIRY DATE: 20.3.2025 
(F) REPRESENTATIONS:   
(i) 36 Individual Representations received objecting to the proposal 
(please see Appendix B for a full 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: 
Landscape and Seascape issues 
Loch Etive is a beautiful natural landscape with dramatic scenery and a popular tourist
destination for this reason which will be impacted by this proposal which will increase the
surface area of the farm. 
Hill walkers will be adversely impacted by the blighting of the natural beauty of the Loch. 
Fish farms are an eyesore and result in a loss of natural beauty and wildlife haven for the
general public. 
Officer comment: the application has been supported by a Landscape and Seascape
Appraisal including photomontage visualisations from key views which concludes that the
impact of the proposed modifications to Etive 2 and Etive 3 will result in at worst ‘moderate’
localised effects. Outwith the local area (1-1.5km) the effects generally reduce to

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Classification: OFFICIAL
’Negligible’, assisted by the removal of Etive 2 and the containment of development in the
area. Furthermore, it is noted that the replacement of the existing ‘hamster wheel’ supported
nets with 120 m circumference pens with pole-mounted top nets are less visually intrusive.
The proposed feeding barge will be low-profile and will be positioned between the land and
the pens to reduce visual impact. The extended mooring area has no effect on visual impact,
due to the submerged location of the equipment. 
Environmental Issues 
Concerns have been raised regarding pollution/contamination from waste discharge
(including uneaten feed, fish excrement and medicine), and impacts on the seabed. 
The sheltered Loch and the narrows at Connel and Bonawe result in a slow turn-around of
water and build-up of effluent. Request for studies to understand this impact. 
Concerns regarding the ‘carrying capacity’ of Loch Etive and potential for irreversible
damage of the seabed. 
Waste generated is dumped in landfill and beaches e.g. ‘gullet’ area of Bonawe. 
Applicant response: SEPA are the responsible authority for determining marine biomass
and medicinal quantities. NewDEPOMOD particle-tracking modelling software is used to
simulate and predict the dispersion of fish farm waste in the benthic environment. This helps
define regulatory limits, ensuring compliance with Environmental Quality Standards. This
modelling has demonstrated that discharges from Loch Etive farms will not increase as a
result of this proposal. The use of chemicals is also regulated by SEPA under the CAR
license. It is also important to note that the post-smolt production strategy which has a
shorter 6 month turn around, coupled with synchronous all sites fallowing of Loch Etive twice
a year, has so far resulted a reduction in chemical usage. 
In relation to dispersive capacity of Loch Etive, water exchange rates in the upper part of
the water column have a flushing time of 2 weeks, perhaps less in times of high rainfall. This
applies especially to dispersal of chemicals. In terms of causing irreversible damage to the
seabed, a recent study conducted at a former Mowi farm site (Loch Ewe) has demonstrated
that seabed recovery can occur in as little as 3 years. 
In response to the issue of farm rubbish on the foreshore, Mowi have responded that regular
beach cleans take place to help address the issue of rubbish on our shores. The Operations
Manager for Loch Etive has responded in a timeous manner when alerted to rubbish (which
is often not farm-derived). 
Officer comment: the applicant has set out proposed operational measures which can
mitigate or minimise the level of risk of potential impacts (including on other aquatic or
coastal interests) to the satisfaction of the Planning Authority. These measures are set out
in the Waste Management Plan, Sea Lice Policy Strategy and Efficacy, Sea Lice –
Implications of Post Smolt Salmon Production for Local Sea Lice Populations, Sea Lice
Medicines and Treatment Times, Sea Lice Medicine Minimisation Statement and Farm
Management Statement. SEPA are responsible for pollution and have not objected to this
application. 
Nature conservation issues 
Concerns raised in relation to the impact on wild migratory species (Atlantic Salmon and
sea trout) due to escapees, water pollution, spread of sea lice and other diseases, noise
pollution.

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Classification: OFFICIAL 
Concerns that brackish water fail to control sea lice and compromise fish health. 
Impacts on wider ecosytems and loss of local biodiversity due to pollution (including impacts
on local mussels/crabs). 
Concerns over Loch warming due to climate change and impacts of pollution. 
Animal welfare concerns for farmed fish. 
Sea lice interactions in relation to wild salmonids. 
Applicant response: Since moving to a post-smolt production strategy coupled with
synchronous fallowing of the loch sea lice levels have reduced compared to previous years. 
Officer response: the applicant has set out proposed operational measures which can
mitigate or minimise the level of risk of potential impacts (including on other aquatic or
coastal interests) to the satisfaction of the Planning Authority. These measures are set out
in the Escapes Contingency Plan, Sea Lice Policy Strategy and Efficacy, Sea Lice –
Implications of Post Smolt Salmon Production for Local Sea Lice Populations, Sea Lice
Medicines and Treatment Times, Sea Lice Medicine Minimisation Statement, Farm
Management Statement and Predator Mitigation Plan. 
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. 
The Planning Authority have been advised by NatureScot.   
Fish welfare is a matter for the Fish Health Inspectorate. 
Economic issues 
Concerns relating to impacts on tourism and the local economy as a result of the proposal. 
Tourists will be put off by the ‘industrial-scale’ farming and impacts on landscape. 
The local employment benefits are minimal and do not outweigh the risk of harm to the
environment, tourism, natural landscape. 
Applicant Response:  The applicant has confirmed that Mowi’s Loch Etive fish farms provide
for 15 direct jobs with more indirect employment provided in geographic support services in
areas such as veterinary health. The total number of direct jobs provided by Mowi across
Argyll and Bute is 81. 
Officer comment: It is noted that fish farming has been established in Loch Etive for many
years, alongside other activities such as minerals workings at Bonawe Quarry. There is no
evidence of an impact on tourism as a result of the proposed activities and furthermore, the
consolidation of fewer, larger pens with pole mounted top-nets and the removal of the Etive
2 pens will result in a positive impact on the landscape compared with the current situation.
It is further considered that the provision of 15 jobs at the site (with more in supply chains)
is a material consideration as a local and community socio-economic benefit. 
Lighting Issues

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Classification: OFFICIAL
Light pollution at night is disruptive to locals. 
Impact of the proposed low-intensity, downward facing LED underwater lights on aquatic
and terrestrial life. 
Applicant response: Assistance to Navigation (AtoN) lights are required by Northern
Lighthouse Board to mark the outer corners of nearly all farm grids. AtoN lights are small
and not very bright, having a nominal range of 2 nm. Vessels will be lit when operations
during the hours of darkness occur. For clarity, underwater lights are placed into pens at
depth over winter/early Spring (when site is not fallow and only for smolts). The entire
mooring area is not illuminated. 
Officer comment:  adequate mitigation is proposed to manage lighting impacts on amenity
and will be secured by a planning condition. 
Noise Issues 
Concerns the proposal will ruin a tranquil area. 
Concerns relating to amenity noise impacts from feeding systems and artificial oxygenation
systems. 
Applicant response: The proposed hybrid barge uses a battery bank so that the generator
does not have to run continuously as no reducing noise. Being able to store large quantities
of feed on the barge reduces vessel traffic further reducing disturbance in the Loch. 
Officer comment:  adequate mitigation is proposed to manage noise impacts on amenity
and will be secured by a planning condition. 
Public Right to Navigate and recreation 
Concerns over safety risks due to exclusion areas around moorings and poorly marked
mooring equipment. 
Restrictions on navigation for recreational users. 
Concerns over mooring area adjacent to private land and slipway in Port Na Mine Bay. 
Impacts on swimming. 
Applicant response: Although the mooring grid is larger than existing, this does not amount
to a material interference with the public right to navigate as the cages and mooring grid
can be easily avoided by exercising normal navigational care. This also applies to the
slipway although the proposed mooring boundary is close to the mooring the closest
proposed anchors are some distance away and being on the seabed would not affect
navigation. 
The mooring area for Etive 3 is separated from the private land by the foreshore (owned by
the Crown Estate). The proposed mooring area is not an exclusion zone, although
avoidance of the mooring grid securing the cages is encouraged. 
Officer comment: see Planning Policy Assessment. 
Safety concerns relating to navigation and shipping

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RIB and larger steel hulled boast navigate the loch constantly during the day which creates
wash which disturbs other users, the shoreline and wildlife. 
RIB traffic also causes noise disruption. 
Underwater wires cause entanglement with other boat lines and fishing lines causing safety
and environmental concerns for wildlife. 
Some objections state that farm vessel activity will increase and that as a result the
likelihood of collisions will also increase. 
The applicant has noted that all staff operating vessels are doing so under RYA
commercially endorsed tickets. 
Officer comment: the consolidation of Etive 2 and Etive 3 into one larger farm with a
permanent feed barge will reduce overall vessel activity on the Loch. 
Over industrialisation and expansion of fish farming on the loch. 
Doubling of the fish farm is not sustainable. Open cage fish farming is unsustainable. 
Other countries are moving towards land-based farming of fish. 
Officer comment: there is no overall increase in farmed fish biomass in the Loch as a result
of this proposal. In addition, SGMD, SEPA and NatureScot have advised the Planning
Authority on this proposal and have raised no objections.   
Sea lice/Wild fish Interactions 
Local fishermen report increases in sea lice within the Loch. 
Concerns over previous high levels of sea lice in Loch Etive in 2021/2022. 
Increases in biomass should not be permitted until the Rural Affairs and Islands Committee
has reported on the matter. 
The District Salmon Fisheries Board recognise the importance of the proposal in relation to
sea lice control and support our proposal. In the short time Mowi have operated a post-
smolt production strategy in Loch Etive there has been a reduction in sea lice. 
Comment:  SGMD have advised the Planning Authority on these matters and have no
objection.  In addition, SEPA has advised that the sea lice exposure risk would not materially
change with the proposed farm in operation. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report: ☐Yes
☒No

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(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:   ☒Yes
☐No 
Planning Application: Overview (Supporting Document)
including: 
Annex 1 Site Plans and Charts 
Annex 2 Community Engagement 
Annex 3 Proposed Plans and Elevations
Annex 4 Equipment Attestation 
Annex 5 Landscape Assessment
Annex 6 ZTV Photomontages
Annex 7 Escapes Contingency Plan 
Annex 8 Sea Lice Policy Strategy and Efficacy Statement
Annex 9 Sea Lice – Implications of Post Smolt Salmon
Production for Local Sea Lice Populations
Annex 10 Sea Lice Medicines and Treatment Times
Annex 11 Sea Lice Medicine Minimisation Statement
Annex 12 Farm Management Statement
Annex 13 Predator Mitigation Plan 
Annex 14 Waste Management Plan
Annex 15 Screening Opinion – EIA Not Required 
(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

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Classification: OFFICIAL 
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
Policy 29 – Existing Fish Farm Consolidation and Rationalisation 
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:
24/00164/SCREEN) was issued by the Council on 23.9.2024.

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Classification: OFFICIAL
(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 
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 36 objections.  Around 40%
of these objections follow the proforma supplied on the ‘Friends of Loch Etive’
website and relate to visual and landscape, pollution, amenity, tourism and
nature conservation impacts. 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 in Loch Etive due to the
proposed removal of the Etive 2 fish farm site. Officers consider that the removal
of Etive 2 is a positive mitigating factor on visual and landscape pollution,
amenity, tourism and nature conservation matters which is not acknowledged in
the majority of the submitted objections. It is further noted that the modernisation
and consolidation of marine fish farming activity at this site is welcomed by
statutory consultees and should be considered as an extension to previously
consented activities. 
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: 
(O)(ii) Soils - Not applicable as this is a marine development

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Classification: OFFICIAL 
(O)(iii) Woodland - Not applicable as this is a marine development    
(O)(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 site is located in Loch Etive to the east of Airds Bay on the southern side
of the loch. The coastline close to the site is designated as ‘Countryside Area’
for the purposes of development management.   It is also designated as the
North Argyll Local Landscape Area. Loch Etive is designated a Marine
Consultation Area by NatureScot. There are Areas of Ancient Woodland to
the south of the site and Special Areas of Conservation for woodland to the
north and south of Loch Etive (designated for Otter). 
This application is for the proposed modification to an existing marine fish
farm for the farming of Atlantic salmon in Loch Etive.  The proposal for Etive
3 (also known as Port Na Mine) would see the existing 10 x 70m
circumference pens replaced with 6 x 120m circumference pens with the
installation of a low-profile feed barge.  The applicant proposes to relinquish
consents and licenses for the nearby Etive 2 site which comprises 8 x 70m
circumference pens in a 2 x 4 formation (n.b. only 6 of the consented pens
are currently installed).  The site would be serviced from the company’s
existing Loch Etive shore base at Inverawe. While the biomass at Etive 3
would increase from 458.4 tonnes to 700 tonnes, this would be due to
transferring biomass from the Etive 2 site, which is to be removed. Initial
screening by SEPA has shown Etive 3 can accommodate this biomass and
has not identified any risk to sensitive features.   
Overall, there would be no increase in farmed fish biomass in Loch Etive as a
result of this proposal. The applicant has further advised that there are a
number of benefits to the proposed modifications which include:
• 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;
• Improved efficiency which will be likely to reduce day-to-day activity in
the loch.  Feed barges will reduce the number of vessels on the loch
each day. 
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 Biodiversity Officer. 
Representations received have been addressed in Section F of this report
(above) and against the planning policies of the adopted Development Plan

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Classification: OFFICIAL
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 
Author of Report: Shelley Gould Date: 5.6.25 
Reviewing Officer: Sandra Davies Date: 5.6.25 
Fergus Murray
Head of Development & Economic Growth

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Classification: OFFICIAL
CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 25/00093/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 9.1.2025, 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 
Proposed equipment co-ordinates Annex 1  23.1.2025 
Existing equipment co-ordinates Annex 1  23.1.2025
Overview of Etive 3 fish farm location
(1:500,000) (Dated 6.6.2024)
Annex 1: Figure
1
A1  23.1.2025
Existing (installed) & Proposed site
(1:10,000) (dated 19 July 2024)
Annex 1: Figure
2  
23.1.2025
Admiralty Chart Existing (Installed) &
Proposed site
(1:10,000) (dated 19 July 2024)
Annex 1: Figure
3
23.1.2025 
Consented & Proposed site
(1:10,000) (dated 19 July 2024)
Annex 1: Figure
4
23.1.2025
Admiralty Chart Consented & Proposed
(1:10,000) (dated 19 July 2024)
Annex 1: Figure
5
23.1.2025
Existing
(installed) and
proposed site
surface
equipment and
mooring/plannin
g
boundaries.(1:5,
000) (Dated
19.12.2024)
Annex 1: Figure
6
23.1.2025
Admiralty Chart
Extract (Existing
(installed) &
proposed site
surface
equipment,
moorings, and
mooring/plannin
g
boundaries)(Dat
ed 19 Dec
2024)(1:5,000)
Annex 1: Figure 7  23.1.2025
Consented &
proposed site
Annex 1: Figure 8  23.1.2025

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Classification: OFFICIAL
surface
equipment and
mooring/plannin
g boundaries
(1:5,000) (Dated
19 Dec 2024)
Admiralty chart
extract:
Consented &
proposed site
surface
equipment and
mooring/plannin
g boundaries
(1:5,000) (Dated
19 Dec 2024)
Annex 1: Figure 9  23.1.2025
Proposed site
surface
equipment,
moorings, and
mooring/plannin
g boundary
(Dated 19 Dec
2024)
(1:5,000)
Annex 1: Figure 10  23.1.2025
Installed site
configuration
permission
(1:1250) (Dated
6.6.24)
Annex 3: Figure 1 0001 23.1.2025 
Site
configuration
permission
16/01972/MFF
(1:1250) (Dated
6.6.24) 
Annex 3: Figure
2
0001 23.1.2025 
Surface cross
section view of
6 circular plastic
pens of 120m
circumference
in a 75m grid.
Side elevation
shows barge
fully unladen
and elevation is
fully
laden.(1:1,250)
(Dated
6.6.2024)
Annex 3: Figure 3 0001 23.1.2025
Typical Pen Design Top Net Support
Option 1 (Dated 6.6.2024)
Annex 3: Figure
4
0001 23.1.2025
Example of Top-Net Support Structure
(Dated 29.1.25)
Annex 3: Figure
5
0002 23.1.2025

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Classification: OFFICIAL
Proposed
Typical Mooring
Design (Dated
6.6.2024)
Annex 3: Figure
6
0001 23.1.2025
Typical Net Design (Dated 6.6.2024) Annex 3: Figure
7
0001 23.1.2025
Example of proposed low profile feed barge
(1:150)
Annex 3: Figure
8
23.1.2025
Example
photograph of
proposed barge
(dated
6.6.2024)
Annex 3: Figure
9
23.1.2025  
Reason: For the purpose of clarity, to ensure that the development is implemented in
accordance with the approved details. 
2. Acoustic Deterrent Devices 
No Acoustic Deterrent Devices (ADDs) shall be deployed at the site hereby approved. 
Reason:  In the interests of nature conservation.  This planning application has been
assessed on the basis that ADDs will not be used. The use of ADDs would be regarded
as a material change to the proposal. 
3. Biomass and Stocking 
The development hereby approved shall not be operated other than with a biomass of
700 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. Relinquishment of Etive 2 site 
There shall be no increase in the biomass of Etive 3 from the previously consented 458.4
tonnes until evidence has been submitted to the planning authority to demonstrate that
the CAR license for Etive 2 has been rescinded to SEPA.  All equipment at Etive 2 shall
be removed within 6 months of receipt of this evidence to the satisfaction of the Planning
Authority. 
Reason: This planning application has been determined on the basis that ‘Etive 2’ site will
be relinquished. 
5 Removal of 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.

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Classification: OFFICIAL 
Reason: In the interest of visual amenity and to accord with LDP2 Policy 29. 
6 Environmental Management Plan (EMP) 
The proposal shall be operated in accordance with the Loch Etive site EMP (5.12.23)
unless superseded by the SEPA National Sea Lice Framework. 
Reason: To ensure the proposal benefits from adequate mechanisms to accord with the
current environmental management requirements as stipulated by the Scottish
Government Marine Directorate. 
7 Waste Management Plan 
The development shall be carried out in accordance with the Port Na Mine Etive 3
Waste Management Plan dated April 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. 
8 Pole Mounted Top Net Specification 
The pole mounted top net system hereby approved shall be as noted below unless
otherwise agreed in writing with the planning authority in consultation with NatureScot. 
This shall be subject to review, underpinned by systematic monitoring.  The Planning
Authority shall be immediately notified in the event of emergence of patterns of
entanglement or entrapment of marine birds. 
Height (m)
Perimeter Pole Support Maximum height of 5m
above the water surface 
Mesh Size (mm)
Sidewall netting from the
bottom to 2m height
18
Ceiling net panel and
remaining sidewall netting
100
Colour Dark grey to black 
Reason:  To minimise the risk to all bird species and to ensure that there are no significant
effects on the qualifying interests of the relevant Special Protection Areas. 
9 Wildlife Recording and Reporting 
The proposal shall be undertaken strictly in accordance with the following criteria: 
(a) Operators shall maintain daily records of wildlife entanglement / entrapment
using a standardised proforma which shall be submitted to the planning authority and
copied to NatureScot at 6 monthly intervals or other specified period to be agreed in
writing with the planning authority in consultation with NatureScot. The first proforma

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Classification: OFFICIAL
shall be submitted 6 months after the development is brought into use unless otherwise
agreed in writing with the planning authority in consultation with NatureScot. 
(b) In the event of any significant entrapment or entanglement of gannets, and any
other SPA interests identified as relevant to a particular fish farm (e.g involving three or
more birds of any named species in any one day and / or a total of ten or more birds in
the space of any seven day period and / or repeat incidents involving one or more birds
on four or more consecutive days), the operators shall immediately notify both the
planning authority and NatureScot; 
(c) Adaptive management approaches should be agreed in writing with the planning
authority in consultation with NatureScot in advance of these being implemented. 
Reason:  In order to ensure that there are no significant effects on the qualifying
interests of the relevant Special Protection Areas.  Gannet have an extensive range and
would have the potential to become entangled in nets. 
10 Update on Biodiversity Enhancement Proposals 
Biodiversity enhancement proposals shall be implemented in accordance with the
details set out in the ‘Further Supporting Information – biodiversity enhancement’
document (submitted by MOWI on 28.4.2025).  Thereafter the applicant shall provide
an annual update on these proposals, unless otherwise agreed in writing with 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. 
11 Predator Mitigation Plan 
The development shall be carried out in accordance with the ‘Port Na mine Etive 3
Predator Mitigation Plan’ dated February 2024 or as updated and agreed in writing with
the Planning Authority. 
Reason:  In the interests of nature conservation. 
12 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. 
13 Lighting 
All lighting above the water surface and not required for safe navigation purposes
should be directed downwards by shielding and be extinguished when not required for
the purpose for which it is installed on the site. 
Reason: In the interest of visual amenity.

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14 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 
15. 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. 
16. Hours of operation 
Except where the planning authority has been notified under the provisions of condition
15 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. 
17. 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 15; 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 28.4.2025). 
All delayed or out of hours operations required to be undertaken outwith the provisions
of condition 15 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. 
18. 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 Loch Etive. 
Reason:  In the interests of nature conservation. 
19. Sea Lice Policy Strategy and Efficacy Statement

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Classification: OFFICIAL 
The development shall be carried out in accordance with the ‘Port Na mine Etive 3 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. 
20. Escapes Contingency Plan 
The development shall be carried out in accordance with the ‘Port Na mine Etive 3
Escapes Contingency Plan’ dated February 2024 or as updated and agreed in writing
with the Planning Authority. 
Reason:  In order to ensure that an acceptable procedure is implemented in the event
of an escape.

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ADDITIONAL NOTES TO APPLICANT 
• 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 MS.MarineLicensing@gov.scot; or
calling 0300 244 5046. 
• Please see consultation response from Northern Lighthouse Board dated 4.3.25
detailing the lighting and marking requirements for the site.

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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/00093/MFF 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. Introduction 
1.1. This application is for the proposed modification to the Port Na Mine (Etive 3) fish farm in
Loch Etive. It is proposed that the number of pens be reduced from 10 x 70 m pens in a
65 m mooring grid in a 5 x 10 formation, to 6 x 120 m pens in a 75 m mooring grid in a 1
x 6 formation. It is proposed to relinquish consents and licenses for the nearby Etive 2
site (comprising 8 x 60m circumference pens in a mooring grid of  2 x 4 formation of which
6 pens are installed).  In addition to the change to the number and size of pens, it is
proposed to install a 200 tonne capacity hybrid feed barge. The site would be serviced
from the company’s existing Loch Etive shore base at Inverawe. 
1.2. The biomass at Etive 3 would increase from 458.4 tonnes to 700 tonnes as a result of this
proposal. However, this is due to transferring biomass from the Etive 2 site which is
proposed to be removed and licences and consents rescinded. Overall, there would be
no increase in biomass in Loch Etive. 
1.3. The sites in Loch Etive were previously used for farming sea trout but since the applicant
MOWI acquired Dawnfresh, the sites have been used for post-smolt production of Atlantic
salmon.  The applicant has advised that post smolt production involves truncated
production cycles which involve growing salmon from 70 – 100 grams, through to about
750 grams over a period of about 6 months.  The fish are then transferred to open water
sea pens.   
1.4. Two other Loch Etive sites managed by DawnFresh/Mowi have recently been
reconfigured in a similar way to the proposals for Etive 3. In August 2024, Etive 4 was
granted consent for the replacement of existing consented 12 x 80m circumference pens
(of which 10 were installed) with 6 x 120m circumference pens, including pole supported
top nets, installation of low profile hybrid feed barge and tidal barrier (24/00523/MFF). In
June 2024, the Etive 6 site was granted consent for replacement of existing 10 x 80m
circumference pens with 6 x 120m circumference pens and installation of replacement
hybrid barge 24/00419/MFF. Both sites are installed and operational. 
1.5. The proposed development is located in Loch Etive to the east of Airds Bay on the
southern side of the Loch. The coastline close to the site is designated as ‘Countryside
Area’ for the purposes of development management.   It is also designated as the North
Argyll Local Landscape Area (LLA). Loch Etive is designated a Marine Consultation Area
by NatureScot. There are Areas of Ancient Woodland to the south of the site and Special
Areas of Conservation for woodland to the north and south of Loch Etive (designated for
Otter). 
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:

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• Just transition;
• Conserving and recycling assets; 
• Local living;
• Compact urban growth;
• 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. 
2.4. With regard to the newly adopted 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. 
2.5. 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. 
2.6. 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 
2.7. NPF4 Policy 32 refers to 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. 
2.8. 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

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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.  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 the criteria from LDP2 policy 28 below with other relevant
policies from NPF4 and LDP2 referred to where they would apply. In this instance, LDP2
Policy 29 – Existing Fish Farm Consolidation and Rationalisation will also 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 Baseline and Initial Appraisal
carried out by Munro Landscape (May 2025).  The appraisal evaluates the landscape and
visual effects the proposed modifications to the Etive 2 and Etive 3 sites and builds on the
previous baseline study and appraisal of marine fish farm sites currently located in Loch
Etive (2024).   
3.6. The appraisal notes that the landscape setting of Loch Etive is richly varied and expansive
in nature and identifies the key potential landscape and visual effects, which could arise
from proposed developments:

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• Potential effects on the landscape and seascape character of the Loch Etive area, as
well as the landscape and seascape character of shoreline and hinterland and
surrounding hillsides; 
• Potential effects upon the Loch Etive mountains Wildland Area; 
• Potential effects upon the North Argyll Local Landscape Area; 
• Potential effects on nearby settlements and views from habitation; 
• Potential effects on views from passing craft within Loch Etive; 
• Potential effects on existing recreational trails and routes passing alongside and in
proximity to the shoreline to either side of Loch Etive; 
3.7. The Landscape assessment sets out ‘The Loch Etive landscape is heavily influenced by
the mountain backdrop and fjord-like form of the sea loch as it cuts a path east and north-
east towards Glen Coe. The eastern section is remote and isolated, without metalled
roads and with little habitation. The loch narrows, with numerous sheltered bays with a
high value the landscape, reflected by the Ben Nevis and Glen Coe National Scenic Area
(NSA) designation. Within this section, to the east of Taynuilt and Bonawe, sit two of the
existing Dawnfresh Farming fish farm sites, Etive 2 & 3 and also the shorebase at
Inverawe. The fish farm sites are in proximity to the southern shoreline, with approximately
600m distance between sites. 
3.8. Both fish farm sites are set against a wooded backdrop on the southern shore, with
broadleaf woodland forming a consistent and soft feature on the shoreline and lower
hillside, and plantation woodland evident within the hillsides above. The land rises steeply
to the south into the lower hills of the Cruachan massif, with a rugged and wild presence.
The shoreline is dark and absorbs the low profile of the pens successfully when viewing
from the opposite shore. Work boats for the fish farm sites are positioned centrally
between the two, and at Etive 2, which is furthest east. The work boats are most notable
from the northern shore and from elevated positions to the southern shore also. Two
dwellings are located to this side of the site, with views over both developments. With the
exception of these dwellings, the sites are remote from settlement. 
3.9. To the east and north-east of the fish farm sites, the loch continues fjord-like into the
mountain interior, with striking views to the peaks of Glen Coe and Ben Starav and into
the National Scenic Area. To the north and opposite shore, the slopes cut steeply up from
a wooded shoreline and lochside track into roughly open and craggy hillside. There is
industrial interest within the quarrying directly behind Etive 2 fish farm site and natural
features of small islands beyond Etive 3. The quarry at Bonawe is a dominant within the
landscape setting, with large rock faces evident below wooded slopes, industrial built form
and spoil mounds down to the shoreline.’ 
3.10. The assessment of the impacts of the proposal on the five identified landscape
character Types (LCTs) and landscape coastal character areas (LCCAs) range from ‘No
effects’, ‘Negligible’ and ‘Minor’ effects on scenic quality, seascape condition, seascape
value, tranquillity, designations, wildness and recreational access. Where the proposals
for Etive 3 would result in ‘Minor to Moderate’ effects these are mostly localised and
experienced within small pockets of the Taynuilt to Rugha Bharr LCCT for Scenic Quality,
Seascape Condition, and on Recreational Access within close proximity only, when
passing beside Etive 3 along the Core paths to the north shore within the ‘Rugged
Mountains’ LCT. These impacts are mitigated by the positive effects identified from the
removal of Etive 2. 
3.11. The removal of Eive 2 has further ‘Positive effects’ for Lower Loch Etive LCCT,
Taynuilt to Rubha Bharr LCCT, Rugged Mountains LCT and Upland Glenns LCT due to
the reduction in the overall extent of developed influence on the Loch. Paragraph 10.15.
of the report also notes that “The removal of Etive 2 will assist in reducing and tempering

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potential adverse effects. Notably, Etive 2 has a greater visual envelope within this LCT
(LCT37: Upland Glenns) and sits within views from Scheduled Ancient Monument Dun
Mor and within greater proximity to Taynault Jetty than Etive 3. Overall Positive effects.’ 
3.12. Furthermore, the appraisal assesses representative visual viewpoints selected within
5km of the site and with intervisibility to the site proposal site: 
Viewpoint Description/Sensitivity  Effect 
Viewpoint 1 (VP01) - Taynuilt Jetty
/ C158 Taynuilt Jetty Core Path 
The old south pier for the Bonawe
ferry crossing. High
Negligible
Viewpoint 12 (VP12) - Parking by
Bonawe Quarry, east aspect
Informal parking near to the quarry
entrance, to the eastern side of
parking area, looking east.
Moderate to High.
Minor
Viewpoint 13 (VP13) - Footpath to
rear of Bonawe Quarry / C156(a)
Bonawe to Glen Etive Core Path
Pedestrian footpath, passing to
the rear of Bonawe quarry and
forming a part of the core path
along the north shore. Moderate to
High.
Positive
Viewpoint 14 (VP14) - Sgeir Lag
Choan / C156(a) Bonawe to Glen
Etive Core Path 
Informal shore access off the core
path to the north side of Loch
Etive. High.
Moderate
Viewpoint 15 (VP15) - C517(a)
Inverawe to Glenkinglass, east
Elevated view from the core path
to the south side of Loch Etive.
High.
Negligible
Viewpoint 18 (VP18) - Dun Mor
Scheduled Ancient Monument
Slightly elevated view from the dun
near to the mouth of the River
Awe. High.
Positive
Viewpoint 19 (VP19) - VP19 –
Airds Bay, north side
From the water’s edge at small
boat launch to north side of Aird’s
Bay. High.
No effects 
3.13. The assessment concludes that the ‘moderate effects’ are localised and concentrated
at VP14, due to the introduction of the proposed feed barge, but that fish farm pens remain
limited in visual presence against the dark shoreline. Visual impacts on residential
receptors at Port Na Mine would be ‘moderate’ and at Airds Bay north side (VP19) would
have ‘No effect’. However, any identified moderate effects are well contained to preserve
the overall integrity of the seascape and landscape of the area of Loch Etive and do not
create significant adverse impacts on the North Argyll Local Landscape Area or on the
Etive Mountains Wildland Area.   
3.14. The supporting information notes that mitigation measures have been embedded into
the proposal.  These include the structures being sited in a simple, ordered contained
layout using muted, matt, non-reflective colours; buoys being dark matt grey in colour in
a simple, ordered layout; avoiding cage mounted storage and associated clutter and the
use of non-intrusive colours for pipes; other than navigational lighting, lighting to be non-
obtrusive and baffled and in use for restricted periods. 
3.15. The appraisal concludes that “the area of the proposed development is a varied and
highly scenic landscape, with abundant recreation and heritage resource. However, the
proposed development is well-sited and detailed to contain effects to low levels on the

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whole, with localised effects only to views and landscape character. The removal of Etive
2 is positive in reducing the overall developed zone and further containing effects to a
suitable degree.” 
3.16. The assessment of the Landscape and seascape Landscape / coastal character,
seascape or visual amenity (including Isolated Coast, Wild Land and National Scenic
Areas) is acceptable in accordance with aquaculture policies 32 d (i) (NPF4), Policy 28 –
Supporting Sustainable Aquatic and Coastal Development, LDP2 Policy 4 – Sustainable
Development, LDP” Policy 8 – Sustainable Siting, LDP2 Policy 71 – Development Impact
on Local Landscape Area (LLA) and LDP2 Policy 72 – Development Impact on Areas of
Wild Land contained within LDP2. 
The natural, built and / or historic or archaeological sites and their settings 
3.17. In terms of Marine Cultural Heritage, there are no features of importance within the
proposed location, although there are a number of assets within 2km.  Historic
Environment Scotland (HES) consider that the proposals have the potential to affect the
following identified Scheduled Monuments (SMs) in particular: 
• SM2527 Dun Mor, motte 380m WNW of Balure Cottage (Scheduled Monument)
• SM3773 Dun Leigh, dun 200m ENE of Balure (Scheduled Monument). 
3.18. HES do not however make specific comments on the impact of these proposals on
these SMs and note instead that this application should be determined in accordance with
national and local policy on development affecting the historic environment, together with
related policy guidance. 
3.19. The submitted Landscape, Seascape Baseline and Initial Appraisal carried out by
Munro Landscape (May 2025) contains a detailed analysis of ‘Visual Receptor Groups –
Heritage’ including SMs and National Record of the Historic Environment (NRHE) sites.
The Appraisal notes at paragraph 11.18. “No SMs are within intervisibility to the proposed
development, and at sufficient distance to encounter no adverse effects upon setting.
NRHE sites within proximity to Port na Mine dwellings (625m to the south-west) will
encounter ‘Negligible’ adverse effects due to slight increase to scale of development
within the seascape. NRHE site on Eilean Duirinnis (1.8km to the west) will encounter
‘Negligible’ adverse effects due to visually weak overall changes to view and setting.
NRHE sites within the promontory of Rubh’ Aird an Droighinn (1.1km to the north-west)
will encounter small-scale adverse effects due to increased developed presence due to
the introduction of the feed barge at Etive 3, but with a reduction in fish farming
infrastructure locally due to the removal of Etive 2. This will result in ‘Minor’ overall adverse
effects. No other heritage sites fall within the 2km visual envelope of the proposed
development. 
3.20. Accordingly, given the proposals will result in an overall reduction of the extent of
development on Loch Etive, and given the ‘Negligible to Minor’ overall impact on the
landscape setting the proposal may be accepted in terms of its implication for the historic
environment.  This would also accord with NPF4 Policy 7 – Historic Assets and Places
and LDP Policy 15 – Supporting the Protection, Conservation and Enhancement of Our
Historic Built Environment, Policy 19 – Schedule Monuments, and Policy 21 – Sites of
Archaeological Importance. 
Designated sites, habitats and species for nature conservation (including Priority   
Marine Features, wild migratory salmonids and European Protected Species). 
3.21. 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

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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. 
The aquaculture specific policies within NPF4 (Policy 32) and LDP2 (Policy 28) also
require consideration of these issues. 
3.22. The proposal is located adjacent to Loch Etive Woods SAC, designated for its
woodland features and otter population. The site’s status mean that the requirements of
the Conservation (Natural Habitats) Regulations 1994 as amended (the “Habitats
Regulations”) apply. Consequently, Argyll and Bute Council is required to consider the
effect of the proposal on the SAC before it can be consented (commonly known as
Habitats Regulation Appraisal). NatureScot advise it is unlikely that the Proposal will have
a significant effect on the qualifying interests either directly or indirectly. An appropriate
Assessment is therefore not required. 
3.23. The proposal has no connectivity with the woodland qualifying interests of the SAC
and therefore no likely significant effect on this feature. Due to the ongoing management
of the site, NatureScot do not believe significant disturbance of the otter qualifying interest
will occur as a result of the proposal. 
3.24. Due to the connectivity between Special Protection Areas (SPA) with breeding Gannet
interest and all Scottish waters used for marine finfish farming, standing advice and
technical guidance is provided in relation to pole supported top nets. An Appropriate
Assessment has been undertaken and is attached at Appendix C of this report. A planning
condition has also been applied to address this matter, requiring reporting of 
entanglement events. 
3.25. NatureScot advise the site is within connectivity of the Priority Marine Feature (PMF)
burrowed mud which has a medium sensitivity for this feature to organic enrichment and
siltation and sets a sensitivity of ‘sensitive’ to synthetic compounds (including pesticides).
The proposal is therefore capable of affecting the feature however, the proposal will not
result in an overall net increase in biomass in the Loch, as Etive 2 is to be relinquished
(which also has connectivity to burrowed mud). Burrowed mud is a widespread habitat in
Loch Etive and any loss or damage to this PMF habitat as a result of the proposal is
unlikely to be significant in the context of the loch as a whole. 
3.26. The proposal is an established site within a Wild Salmonid Protection Zone, due to the
proximity of water courses that form migratory routes sea trout and migratory wild salmon
(e.g. River Kinglass and smaller Rivers Noe and Liver, Abhain Dalach and Alt Easach are
primarily habitats for recruitment of sea trout). In line with NPF4, Policy 3: Biodiversity (a)
and (d) and Policy 4: Natural Places (b) and (e), the applicant has considered lice
connectivity throughout all sites in Loch Etive within their Implications of Post-Smolt
Salmon Production for Local Sea Lice Populations Report (January 2023).  The applicant
has committed to implement a monitoring programme either through the current
Environment Management Plan or through any subsequent National Sea Lice Framework
to be implemented, of the salmon population in Loch Etive with a feedback adaptive
management loop to the farm operation. 
3.27. For Etive 4 and 6 (to the west of the site) the applicant has changed the production
strategy for Loch Etive from Rainbow trout to a post smolt stocking model for Atlantic
salmon.  This entails stocking with Atlantic salmon for short periods of around six months
with a full fallowing period of four weeks synchronously across all sites in the loch. These
short production cycles and the increase in fallow periods are intended to address
previous sea lice issues and improve sea lice management.  SEPA has confirmed that
the modelling provided suggests that this stocking strategy would reduce the need for
further sea lice interventions and avoid the high lice numbers overserved during the

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second summer at sea thus maintaining numbers of adult females below the CoGP
suggested criteria for the duration of the production cycle.  Historically when Rainbow
trout were stocked, Loch Etive was rarely stocked synchronously and this impacted on
sea lice levels. 
3.28. These approaches will be adopted for Etive 3 and an Environmental Management Plan
(EMP) is in place for all of the Dawnfresh sites in Loch Etive under previous consents.
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 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 framework mechanisms
not be implemented within 6 months of the granting of planning permission. 
3.29. 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. 
3.30. 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 
3.31. NPF 4, Policy 3 – Biodiversity, requires developments to contribute positively to
biodiversity enhancement.  In addition, the applicant is committed to undertaking further
off-site biodiversity enhancements in the form of a cooperation agreement with the Argyll
District Salmon Fishery Board to support a Fishery Management Plan 2025-2026 for the
Awe catchment which is located on the south side of Loch Etive in Argyll and flows into
the Firth of Lorn on the West coast of Scotland. The Awe catchment is the largest in the
Argyll and Islands region and supports recreational fisheries for Atlantic salmon which are
managed by the Awe District Rivers Improvement Association (ADRIA) overseen by the
Argyll District Salmon Fishery Board (Argyll DSFB). 
3.32. As part of this project, the applicant confirms that a catchment-wide juvenile fish survey
was carried out in 2024 by the Argyll Fisheries Trust with the aim of informing a
management plan for fisheries and other resources in the Awe catchment area. The
applicant will provide funding to support delivery of two projects of the Awe Fishery
Management Plan for 2025-26 as follows: 
1. Identify and implement mitigation actions (Inverawe Hydro and Cruachan pumped
storage hydro schemes) to improve Atlantic salmon smolt survival. Initial studies show
that only 20 % of smolts can find their way to the sea. This project aims to: 
• Identify factors affecting the passage of smolts in Loch Awe & River Awe. 
• Identify solutions to delay and mortality of smolts. 
• Work with hydro scheme operators to implement identified mitigation.

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2. Restore productivity of freshwater habitats: Produce and implement habitat
improvement plans for sub-catchments of the Awe. Juvenile fish and habitat surveys
have identified sub-catchment habitats that require Improvement. This project aims to: 
• Identify suitable areas for fencing / planting. 
• Agree mitigation-enhancement solutions with landowners. 
• Implement habitat improvements (such as riparian planting). 
3.33. 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. 
3.4 Ecological status of coastal and transitional water bodies and biological carrying
capacity (water quality & seabed impacts). 
3.34. Surveys have shown that the area of impact from farm activity has remained within the
immediate site vicinity. NewDepomod modelling indicates the Environmental Quality
Standards for waste solids will be met using the proposed layout. The proposed offset in
biomass at Etive 3 by relinquishing the Etive 2 site would result in a net decrease in
biomass of 8.4 tonnes, meaning the nutrient enhancement index would not change. SEPA
confirms that none of the Priority Marine Features within the vicinity of the farm are
considered at risk from the proposal for issues within SEPA’s remit and that sea lice
screening has been undertaken and has shown minimal effect on the exposure risk. 
3.35. SEPA has confirmed the proposed biomass is reasonable within the scope of the new
regulatory framework and have confirmed that an application for a CAR permit was
submitted on 27.3.2025 (determination pending). 
3.36. SGMD have advised that regarding water column impact, nutrient impacts have been
assessed previously and as there is no overall increase in biomass, there is no
requirement for any further assessment regarding impacts to the water column. 
3.37. 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). 
3.38. With regard to impacts on commercial activity and navigation within Loch Etive, these
are reduced by the fact that the 4 largest marine fish farms are operated by the same
parent company, Mowi Scotland, providing oversight and consistency in procedures (e.g.
synchronised fallowing). In addition, navigation of larger vessels in the Loch is difficult due
to the height of the Connel bridge and larger vessels are required to be guided into the
area. As such there are limited impacts on commercial maritime activities and navigation. 
3.39. With regards to anchorages, The Royal Yaught Association (YHA) advised they have
no objections to the proposed modifications to Etive 3. As such it is concluded that there
would be minimal impacts on recreational marine vessels within the local area and in
addition, the proposed removal of Etive 2 would further improve recreational navigation
in this location. The proposal will not present adverse navigational safety issues, subject
to navigational marking to satisfy Northern Lighthouse Board requirements. 
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.

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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 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 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
relatively devoid of human habitation, with only one property directly overlooking the site
to the south of the Loch.  Other potential receptors for noise would be walkers on the
Bonawe to Glen Etive Core Footpath (C156(a)) on the northern side of the Loch and
C517(a) Inverawe to Glenkinglass: on the southern side. It is noted that the Bonawe
Quarry is an existing contributor to background noise levels. 
3.43. 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. The proposal seeks
permission to install and operate a hybrid-powered feed barge. Data collected from the
same design barge presently operating at the Etive 4 fish farm has shown that, between
August - March 2025, the barge was powered by battery 77% of the time. This is
equivalent to an average generator use of 5.6 hours/day. This has also resulted in a 48%
reduction in fuel/CO2 use/emissions. The ability to power the feed barge via stored battery
energy allows operational flexibility to avoid generator running during noise sensitive
times of the day. 
3.44. A number of different vessels will continue to support day-to-day operations at the new
farm location throughout various stages of the production cycle. The vessels will
undertake routine husbandry and maintenance activities, including grading, administering
treatments, and harvesting. Currently the Etive 3 fish farm is fed from a boat, using feed
cannons therefore the use of a feed barge would reduce day to day vessel activities
associated with feeding and discontinue the use of feed cannons as a noise source. The
reduction in pen numbers will also reduce the frequency of other husbandry operations
such as net washing. A reduction in daily husbandry activities and associated vessel
operations due to consolidation will reduce noise emissions overall. 
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.  This primarily includes 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)

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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’ statement submitted 28.4.2025): 
• 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. 
• 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 proposed feed barge will have
to display 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. 
Waste management 
3.50. With regard to waste, a Waste Management Plan is currently in place for the Etive 3
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.

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3.51. Given the location of the proposed development sufficiently far away from sensitive
receptors, it is not considered that there would be any adverse effects from odour. 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 and then transferred to the approved site incinerator plant for further
treatment prior to uplift by a licensed waste carrier for disposal at a licensed facility. There
will be no net increase in overall biomass produced in the Loch Etive sites arising from
the development proposal and no increase in volume of waste produced anticipated.
There will be no material change to existing processes dealing with mortality disposal in
the farm management area. 
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. 
3.54. Net economic impact, including local community socio-economic benefits such
as employment, associated business and supply chain opportunities. 
3.55. Scottish Planning Policy 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. For example, Mowi’s Loch Etive fish farms
provide for 15 direct jobs with more indirect employment provided in geographic support
services in areas such as veterinary health. Mowi provides 81 direct jobs across Argyll
and Bute, with an average basic salary of £35,059. Recognising the importance of
developing and recruiting their workforce from within Argyll and Bute, Mowi is working
with UHI Argyll in partnership with Salmon Scotland and other farming companies to
develop and deliver an Aquaculture SCQF4 academic qualification. The practical element
of this to be delivered in Campbeltown, Lochgilphead and Oban High Schools, with work
experience opportunities to be provided with a producer company supporting a trajectory
towards securing employment within the sector.

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Annual Operational Expenditure 
3.57. The Loch Etive Fish Farms have a cumulative operational annual expenditure of £15M
in 2024. This includes key local expenditures such as labour (£760k), repair and
maintenance (£863k), other direct costs (£1.575M) and indirect costs (£364k); a total of
£3.56 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 Argyll and Bute council area. With innovation in pen design and with improving
design and capacity of support vessels Mowi has been upgrading pen equipment across
Scotland since 2022 to achieve operational efficiencies and improve health and welfare
for farm reared salmon. 
Proposed Capital Expenditure Arising from the Development Proposals 
3.58. The total capital expenditure for the development proposals for the Etive 3 fish farm
incorporating the new equipment, comprising 6 x 120m pens, 6 x fish nets and new
moorings, grids and associated components is approximately £1.2 million. 
Economic Value of Aquaculture to Argyll and Bute 
3.59. 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. 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. A regional breakdown of annual figures by the sector’s trade
body Salmon Scotland confirms that an estimated 15,041 tonnes were exported from
Argyll and Bute in 2024, representing around 18 per cent of Scotland’s total exports. There
are 109 aquaculture operations across Argyll and Bute, the majority being seawater
operations. The sector directly supports 540 jobs in Argyll and Bute, with local fish farms
such as the Mowi Loch Etive sites forming part of the economic backbone of rural
communities. 
3.60. 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 or manage risk through adaptive management in
response to environmental monitoring. 
3.61. 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.

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3.62. With regard to sustainable site management, the proposed barge will reduce carbon
emissions through the use of hybrid technology to power the barge.  This is in line with
the aims of NPF 4 Policy 1 and Policy 2 which seek to encourage development which
minimise emissions from developments.  It would also accord with LPD2 Policy –
Sustainable design which is supportive of renewable sources of energy. 
3.63. In terms of sea lice management and the control of risk, the applicant has submitted
supporting information entitled “Implications of Post-Smolt Salmon Production for Local
Sea Lice Populations”.  This report explains that post-smolt production involves truncated
production cycles, growing salmon from salmon from sixes of 70 – 100 g through to about
750 g over a period of about six months.  The fish are then transferred to open water
pens, when on-growing to harvest size takes place.  The Report notes that post-smolt
production in inshore waters has the potential to reduce sea lice levels in local waters
because of the reduced time the fish are at sea and the regular fallowing engendered by
the short production cycles.  The regular breaks in production and regular re-stocking with
lice-free fish prevents lice populations building up to reportable levels. 
3.64. The substantial reduction in lice numbers on the farmed fish has two principal benefits:
the risk to wild fish migrating through Loch Etive from infective lice larvae is substantially
reduced, and second, the need for medicinal treatments is also substantially reduced, if
not obviated. In conclusion, the modelling study suggests that switching production in
Loch Etive from traditional farming of rainbow trout to production of post-smolt Atlantic
salmon is likely to have significant benefits for both the farmed fish and the local wild fish
populations. 
3.65. Fewer, larger pens as proposed 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. In support of this application, the company has
submitted the following documents: 
• Sea Lice – Policy, Strategy and Efficacy Statement which outlines the measures
the company will take to reduce sea lice. 
• Sea Lice Medicines and Treatment Times
• Sea Lice Medicine Minimisation Statement 
• Farm Management Statement
• Escapes Contingency Plan 
3.66. An Environmental Management Plan (EMP) is in place for all of the Dawnfresh sites in
Loch Etive under previous consents. 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 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 framework mechanisms not be implemented within 6 months of the
granting of planning permission. 
3.67. SEPA and SGMD have no objections to the proposals and SEPA has confirmed the
proposed biomass is reasonable within the scope of the new regulatory framework and
have confirmed that an application for a CAR permit was submitted on 27.3.2025
(determination pending).

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3.68. It is considered that the proposal would comply with this element of LDP2 Policy 28
and NPF Policy 32. 
Proposed operational measures which can mitigate or minimise the level of risk of
potential impacts (including on other aquatic or coastal interests). 
3.69. In addition to the documents to outline the applicant’s proposed approach to managing
sea lice (see above), a number of documents have been submitted which relate to the
operation of the site.  These include: Escapes Contingency Plan, Farm Management
Statement, Predator Mitigation Plan; and 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. 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.

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APPENDIX B – LIST OF CONTRIBUTORS 
OBJECTIONS
1. Chrissie Grant No address given  (11.03.2025)
2. Richard Harrap No address given (11.03.2025)
3. Charles Denvir Ivy Cottage Pandy Abergavenny NP7 8HH  12.03.2025
4. Lady Claire Greenaway The Coach House Lois Weedon Towcester NN12 8PJ
12.03.2025 
5. Nathalie Service No address given       20.03.2025
6. Veronica Barry Tigh Na Mara Bonawe Argyll And Bute PA37 1RL
21.03.2025 
7. Alex Burns 3 Birchlea Drive Giffnock G46 6BP 10.03.2025
8. Maude Caldecott No address given 11.03.2025
9. Iona Gibson No address given 11.03.2025
10. Hazel Barry The Kestrel Bonawe Argyll And Bute PA37 1RL 24.03.2025
11. Miss Freya Macmillan Muckairn Castle Muckairn Estate Taynuilt Argyll And Bute
PA35 1JA 17.03.2025
12. Archie McIntyre 3 Exmoor Close Tiverton EX16 6UR 20.03.2025
13. William Marshall 51 Inglis Green Road Longstone Edinburgh EH14 2EY
25.03.2025 
14. Mrs Carol Burnside 45 Nant Drive Oban Argyll And Bute PA34 4NL
25.03.2025
15. Mrs Camilla Trant Cefn Du Welshpool SY21 9ER
16. Peter Dunlop 3 Douglas Gardens Mews Edinburgh EH4 3BZ 11.03.2025
17. James Bolam New Pound Lane Wisborough Green RH14 OEG
12.03.2025
18. Susan Greenaway Lois Weedon House Towcester Northants NN12 8PJ
12.03.2025 
19. Susan Jameson No address given 12.03.2025
20. Mr Frazer Fowler Muckairn Castle Muckairn Estate Taynuilt Argyll And Bute PA35
1JA 
21. Thomas Greenaway The Coach House Towcester Northants NN12 8PJ 13.03.2025
22. Ms Sandrine Chadwick The Factors House Muckairn Estate Taynuilt Argyll And Bute
PA35 1JA 18.03.2025
23. Peter Barry Tigh Na Mara Bonawe Oban Argyll
And Bute 
24. Kathleen Hannigan No address given 11.03.2025
25. Abigail Penny 124 City Road London EC1V 2NX
24.03.2025
26. Malcolm Young No address given 25.03.2025
27. George Brew No address given 25.03.2025
28. David Brew No address given   25.03.2025
29. Mr Alan McKnight 35 Stewart Drive WHITBURN
EH47 0EN 
30. Ronnie Campbell Bonawe 14.04.2025
31. Karima Mould Ivy Cottage Pandy Abergavenny NP7 8HH 11.03.2025
32. Mr Edward Clifton-Brown Manor Farmhouse East Beckham Norwich
NR11 8RP 10.03.2025
33. John Gore Tigh Na Ba Taynuilt Argyll 11.03.2025
34. Maggie Service The Cottage 1 Crescent Wood Road London SE26 6RT 11.03.2025
35. Helena Gore Portnamine Tigh Na Ba Taynuilt Argyll 11.03.2025
36. Kathy Longbottom No address given 11.03.2025

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APPENDIX C – APPROPRIATE ASSESSMENT (25/00093/MFF). 
Ailsa Craig SPA: Appropriate Assessment by Argyll and Bute Council under
Regulations 9A and 11-15 of The Conservation (Natural Habitats, &c.)
Regulations 1994 as amended by the Conservation (Natural Habitats, &c.)
Amendment (Scotland) Regulations 2011 
APPRAISAL IN RELATION TO REGULATION 48 OF THE CONSERVATION (NATURAL
HABITATS, &C.) REGULATIONS 1994 AS AMENDED (HABITATS REGULATIONS
APPRAISAL) 
EUROPEAN SITE DETAILS
Relevant European site qualifying interest: 
Name of European site(s) potentially affected: 
Conservation Objectives for qualifying interests: 
The Conservation Objectives for each site can be accessed via SiteLink. erio 
STAGE 1: WHAT IS THE PLAN OR PROJECT 
Use of pole-mounted top net systems with ceiling mesh dimensions of 100mm or less at
existing finfish aquaculture sites in Scotland (Port Na Mine/Etive 3). 
STAGE 2: IS THE PLAN OR PROJECT DIRECTLY CONNECTED WITH OR NECESSARY
TO SITE MANAGEMENT FOR NATURE CONSERVATION? 
No 
STAGE 3: IS THE PLAN OR PROJECT (EITHER ALONE OR IN COMBINATION WITH
OTHER PLANS OR PROJECTS) LIKELY TO HAVE A SIGNIFICANT EFFECT ON THE
SITE? 
Breeding gannets have a mean foraging range of 120.4km (±50.0km) and a mean maximum
foraging range if 315.2km (±194.2km).  Consequently, there is potential connectivity between
gannets from one or more of the SPAs listed above and all Scottish marine waters suitable for
finfish aquaculture.

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There is potential for Likely Significant Effect (LSE) arising from incidental entanglement or
entrapment of gannets at finfish farms deploying pole-mounted top nets. 
STAGE 4: APPROPRIATE ASSESSMENT OF THE IMPLICATIONS FOR THE SITE IN
VIEW OF ITS CONSERVATION OBJECTIVES 
Gannets forage opportunistically on pelagic fish shoals by plunge diving into them from the air
and pursuing fish underwater.  They may be attracted over substantial distances by presence
of other gannets, such that large numbers of birds can quickly gather over a fish shoal.  There
are several known instances of numbers of gannets becoming entangled and entrapped at
finfish farms when attempting to plunge dive into stocked cages through pole-mounted top
nets.  Entangled birds may suffer fatal injuries and entrapped birds are subject to stress when
confined or during subsequent release by site operators, with unknown longer term
consequences for individual survival or breeding success. 
Such interactions with pole-mounted top net systems have potential to undermine
maintenance of gannet populations as viable components of relevant SPAs, through
negatively impacting population level adult survival rates and / or breeding success. 
The population of gannets in Scotland is large (243,505 pairs in 2013-14) and continues to
grow rapidly (2.9% per annum between 2003-4 and 2013-14).  All SPA populations are
currently in Favourable Conservation Status with stable populations, as detailed below: 
Given favourable status and dynamics of gannet populations, high levels of mortality of
breeding of adults would be required to undermine SPA conservation objectives. 
There is currently limited empirical information on interactions between gannets and pole-
mounted top nets, but the incidents we are aware of involving multiple birds have been
associated with ceiling mesh sizes of 200mm or greater.  The adoption of ceiling mesh
dimension of 100mm or less is considered, on both theoretical grounds and in light of the
currently available evidence, to pose low risk of damaging interactions with gannets. 
STAGE 5: CAN IT BE ASCERTAINED THAT THE PROPOSAL WILL NOT ADVERSELY
AFFECT THE INTEGRITY OF THE SITE? 
It is concluded that there is no Adverse Effect on Site Integrity with respect to breeding gannet
populations associated with permitting the adoption of pole-mounted top nets with ceiling
mesh dimensions of 100 mm or less at existing finfish aquaculture sites in Scottish waters. 
The conclusion is however subject to strict planning conditions being applied to all relevant
consents (as outlined below and detailed in associated Standing Advice) to ensure

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avoidance of future Adverse Effect in Site Integrity, including consideration of cumulative and
in-combination effects. 
Additional – to that outlined in Stage 4 – mitigation or modifications that are required to
ensure adverse effects are avoided and the reasons for these are set out below: 
CONCLUSION / ADVICE IN RELATION TO PLAN OR PROJECT 
In line with the advice provided by NatureScot, subject to the imposition of appropriate
conditions on the grant of any planning permission, it is considered that no
unacceptable impacts will occur to the Ailsa Craig SPA or other interconnected SPAs
by the grant of this proposed planning permission. 
The use of pole-mounted top net systems with ceiling mesh dimension of 100 mm or
less at existing finfish aquaculture sites in Scotland can be therefore permitted.