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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Classification: OFFICIAL 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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Classification: OFFICIAL (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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL • 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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Classification: OFFICIAL 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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Classification: OFFICIAL • 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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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Classification: OFFICIAL 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.