20241113_PPSL Committee, 09/12/2024 Pre-Agenda Briefing of the Planning, Protective Services and Licensing Committee
Argyll and Bute Council · 18 December 2024
Back to Planning, Protective Services and Licensing Committee — 18 December 2024 and its agenda
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MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE held ON A HYBRID BASIS IN THE COUNCIL CHAMBER, KILMORY, LOCHGILPHEAD AND BY MICROSOFT TEAMS on WEDNESDAY, 13 NOVEMBER 2024 Present: Councillor Kieron Green (Chair) Councillor John Armour Councillor Gordon Blair Councillor Jan Brown Councillor Graham Hardie Councillor Fiona Howard Councillor Mark Irvine Councillor Andrew Kain Councillor Dougie Philand Councillor Peter Wallace Attending: Shona Barton, Governance Manager Iain Jackson, Governance, Risk and Safety Manager Peter Bain, Development Manager – Planning Sandra Davies, Major Applications Team Leader – Planning Ian Laister, Managing Director, Bakkafrost Scotland – Applicant Craig Johnston, Site Manager, Bakkafrost Scotland – Applicant Freddie Parffrey, Environmental Officer, Bakkafrost Scotland – Applicant Dave Cockerill, Biology Director, Bakkafrost Scotland - Applicant Penny Hawdon, Site Development Manager, Bakkafrost Scotland – Applicant Zane Pretorius, Area Manager, Bakkafrost Scotland – Applicant Tony Philpin, Gigha Community Council – Consultee (also Objector) Marion Stevenson, Gigha Community Council – Consultee Lorraine Holdstock, Marine & Coastal Development Policy Officer – Consultee Audrey Dickie, Supporter 1. APOLOGIES FOR ABSENCE Apologies for absence were received from Councillors Audrey Forrest, Amanda Hampsey, Paul Kennedy and Liz McCabe. 2. DECLARATIONS OF INTEREST There were no declarations of interest. 3. BAKKAFROST SCOTLAND LTD: FORMATION OF FISH FARM (ATLANTIC SALMON) INCORPORATING 8 X 160M CIRCUMFERENCE CIRCULAR CAGES AND SITING OF FEED BARGE: GIGHA FISH FARM, WEST OF ISLE OF GIGHA (REF: 23/01758/MFF) The Chair welcomed everyone to the meeting, which was held on a hybrid basis. For the purposes of the sederunt Shona Barton, Clerk to the Committee today, read out the names of the Members of the Committee and asked them to confirm their attendance. In advance of the meeting today, interested parties confirmed they would make presentations to the Committee. Mrs Barton read out the names of those representatives and asked them to confirm their attendance. Mrs Barton also clarified that there was no one else in attendance today that wished to speak.
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The Chair explained the hearing procedure that would be followed and invited the Planning Officer to present the case. PLANNING On behalf of the Head of Development and Economic Growth, Sandra Davies, Major Applications Team Leader, made the following presentation with the aid of power point slides. Firstly, I would like to advise Members that I have received a late representation from Marion Stevenson which makes reference to the fact that the comments made by supporters and summarised in Supplementary Report number 2 make reference to the age and status of objectors. The points summarised in the supplementary report relate to the comments made by third party supporters and are not the views of Officers. It is confirmed that in assessing the application, it is the issues raised and their materiality to planning, rather that the status of representees that are taken into account. This application is for the installation of a new marine fish farm for the production of Atlantic salmon in the Sound of Jura approximately 450 m to the west of the Isle of Gigha. The site would comprise 8 x 160m circumference pens in a 2 x 4 formation along with a 600 tonne feed barge which would be located at the centre of the group on the shore side. Slide 4 Site Layout with moorings doc 23003293 This drawing shows the mooring plan associated with the cages and barge. Slide 5 doc single cage example The cages would be low in profile and finished in a dark, non- reflective material. This slide shows the details of a single pen. Slide 6 Typical Pen Design This plan shows a typical pen design with pole mounted top nets and pen netting. Slide 7 Feed Barge Here is an image of the proposed 600 tonne feed barge which has a design akin to a marine vessel. Slide 8 – EIA Front Cover An Environmental Impact Assessment has been carried out in relation to this application. The EIA process looks at the significant effects of a project on the environment. SLIDE 9 LDP 2 and NPF4 Cover As with any other type of planning application, the legislation requires that the proposals be assessed against the policies of the development plan. If the proposal accords with these policies then the development should be approved unless material considerations indicate otherwise.
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The Development Plan comprises National Planning Framework 4 (NPF4) adopted February 2023 and the Argyll and Bute Local Development Plan adopted 2024. A number of NPF4 policies apply to this development, however, the prime policy for aquaculture is policy 32. This policy makes it clear that LDPs should guide new aquaculture development in line with National and Regional Marine Plans. They should minimise environmental impacts, including cumulative impacts, that arise from other existing and planned aquaculture development in the area whist also reflecting industry needs. Policy 32 requires the consideration of a set of criteria which are similar to those covered the LDP2 aquaculture policy 28. Slide 10 Policy 28 text 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 has therefore been assessed against the criteria from LDP2 policy 28 with other development plan policies referred to where they would apply. I will now go through each of the bullet point criteria listed in this policy. Slide 11 - Landscape / coastal character, seascape or visual amenity (including Isolated Coast, Wild Land and National Scenic Areas) The first criteria to be considered under this policy relates to landscape / seascape and visual amenity. A seascape, landscape visual impact assessment has been included with the EIAR. The SLVIA explains that the level of effect, and whether this is significant, is determined through consideration of the ‘sensitivity’ and ‘susceptibility’ of factors including: • The seascape, landscape element, assemblage of elements, key characteristics or character type or area under consideration bearing in mind quality and value; or • The visual receptor; and • The ‘magnitude of change’ posed by the development. Effects predicted to be of major or moderate significance are considered to be ‘significant’ in the context of the EIA Regulations. Following the submission of this planning application, it came to light that the Western Link footpath was incorrectly plotted. In response to this further supplementary environmental information was provided by the applicant and duly advertised in accordance with the EIA Regulations. This update established that : • Section 2 of the Western Link is approximately 4.5km long and it is at times located closer to the coastline than indicated on mapped sources; • The view of the fish farm would occur for a shorter length of the footpath than previously described, 0.98km as opposed to 1.2km; • The nature of views of the proposed development in combination with features such as the hill forms of Islay and Jura and the wider seascape vary depending on which stretch of the footpath the viewer is on as exhibited by Viewpoints 3 and 6;
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• The magnitude of change and level of effect as reported in the SLVIA for users of the Western Link would be largely unchanged. • SLIDE 12 - Residential Properties, Settlements and Core Path (original version) doc no 23003345 This drawing shows the original document submitted which has the incorrectly plotted western link footpath. The purple shading is the area which would have the greatest visibility of the fish farm. The blue line is the western link footpath. SLIDE 13 - Residential Properties, Settlements and Core Path (corrected version) This drawing shows the route of the corrected link footpath. The closest residential properties to the site are also plotted. Slide 14 – Map of View Points -This plan shows the selected viewpoints along with the zone of theoretical visibility or ZTV for short. The dotted rings around the site show the 1km, 2km and 5km distance around the site. Slide 15 – Cumulative ZTV map -This is a cumulative ZTV plan which takes account of the two existing fish farms which are shown plotted to the east along with the proposed development. The purple shading shows the area where all the fish farms could be viewed from the same point. Slide 16 – VP Locations To aid the evaluation of visual effects, a number viewpoints were selected as part of the Seascape and Landscape VIA. This plan shows where all the various VP locations are. I will now run through the various viewpoints. This Zone of Theoretical Visibility Map also shows where views of the fish farm are likely to be experienced. The purple area has the greatest visibility. I will now take you through the visualisations contained within the SLVIA. These visualisations are not designed to be viewed on a computer screen. Members have been issued with paper packs of visualisations but I have also included them in this presentation so it is easy to follow which one I am referring to. Slide 17 – Twin Beaches Baseline -The first VP is from the twin beaches. The small inset at the bottom right hand corner of the photograph shows the direction that the photo was taken in. This viewpoint was selected to illustrate the landscape / seascape context and views from a beach area on the Isle of Gigha. The viewpoint is representative of views available for visitors to the beach, northeast of the Proposed Development. This location is 4.41km from the site. Slide 18 Twin Beaches Wireline -This next slide is a wireline drawing. It is a computer generated image which shows the topography along with the proposed development but does not include vegetation. Slide 19 Twin Beaches Visualisation -This is the visualisation for this VP. The fish farm is visible in the centre of the screen. Slide 20 – Ardailly Baseline VP2 -This is VP2 which is located in the vicinity of the residential property at Ardailly. As you can see there is no visibility to the sea from here.
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This viewpoint was selected to illustrate the landscape / seascape context and views from the front of a residential property. The viewpoint is representative of views from the path / small garden area / front elevation of the property, northeast of the proposed development. The VP is 1.36km from the proposed fish farm. Slide 21 – Ardailly Wireline -This is the associated wireline. As there is no visibility of the fish farm there is no visualisation for the view point. Slide 22 – Western Link Footpath – south east of the site -This is a photograph taken from the Western Link footpath south east of the site. You can see the island of Islay and Jura in the distance. This VP is representative of views for recreational users in this locally promoted footpath. It is 0.65km from the site. Slide 23 – Western Link Footpath wireline -This is the wireline from this footpath with the fish farm cages and barge shown. Slide 24 – Western Link Footpath visualisation -And this is the visualisation from the third and closest viewpoint to the proposed development. Slide 25 – Local Road and Core Path Baseline -This viewpoint has been included to illustrate the views from the local road which is also a core path. This viewpoint contains some views of the existing fish farms to the east as well as in the direction of the proposed development. Slide 26 – North East view VP 4 - This is the view to the north east with partial views of a one of the existing fish farms on the east of the island; Slide 27 – South East view VP 4 - This view is to the south east which gives a greater view of the existing fish farm on the east of Gigha at Druimeyeon Bay. Slide 28 – South West view VP 4 - This photograph looks south west towards the proposed development. Slide 29 – South West view VP 4 wireline - This is the wireline photograph which shows the location of the proposed development. Slide 30 – VP 4 visualisation - And this is the visualisation for VP 4 looking towards the proposed development. Slide 31 - VP 5 Cnoc no Gobhar - This viewpoint was selected as it was a high point on the island. This is a cumulative viewpoint which is located 4.66km from the proposed development. Slide 32 - VP 5 looking northwest - This is the base line looking north east. Slide 33 - VP 5 looking south east - This photograph is taken looking south east and here you can clearly see the two existing fish farms off the east coast. The land beyond is the mainland of Kintyre. Slide 34 - VP 5 looking south west - This photograph looks towards the proposed development. Slide 35 - VP 5 wireline - This wireline shows that there may be visibility of the proposal.
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Slide 36 - VP 5 visualisation -…and here is the visualisation. Slide 37 - VP 6 Western Link east of site - This is another viewpoint from the western link footpath. This one is 0.7km from the proposed development. Slide 38 - VP 6 Wireline - This is the wireline. Slide 39 - VP 6 Visualisation - and this is the visualisation. Slide 40 - VP6 Public Footpath travelling south to north – general view - This photograph shows a further typical view when walking the western link footpath for south to north. The walker would need to turn round and look back the way to see the fish farm. Slide 41 - VP 7 Dun An Trinnse baseline - The VP represents a view from the coastline at a distance of 1.39km. You can also see the residential properties at Ardailly. Slide 42 - VP 7 Dun An Trinnse wireline - This is the wireline drawing. Slide 43 - VP 7 Dun An Trinnse visualisation - And this is the visualisation. Slide 44 - VP 8 Creag Bhan north west - This is a view form the highest summit on Gigha. It is located 1.8km from the proposed development and is included within the core path route. This is the view looking north west. Slide 45 - VP 8 Creag Bhan - From the same spot looking north east. You can see the two existing fish farms on the east of the island in this this photograph. Knapdale and Kintyre can be seen beyond along with the gap into WLT. Slide 46 – VP 8 Creag Bhan south east - Again the same spot looking south east. Slide 47 – Looking south west - This photograph looks towards the proposed development. Slide 48 - VP 8 Creag Bhan south west wireline - Here is the wireline for the south west view. Slide 49 - VP 8 Creag Bhan south west visualisation -.and here is the visualisation from Creag Bhan Slide 50 VP 9 – on water west of Gigha - This is a viewpoint taken from the sea looking towards the proposed development and Gigha. The selected viewpoint is 1.8km from the site. Slide 51 – VP 9 Wireline - This is the wireline from the sea. Slide 52 – The visualisation from the sea. Slide 53 - VP 10 Residential - The final two slides are from residential properties and illustrate that there will be no directed views of the site. Slide 54 – VP 10 wireline
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Slide 55 – VP 11 Residential property Slide 56 – VP 11 wireline In terms of landscape and seascape effects, the SLVIA concludes that in line with NatureScot’s guidance on aquaculture, the proposal would be well sited within the seascape and set against a backdrop of islets and rocky coastline within an open seascape which should help to ‘absorb’ the man-made structures into the seascape. It is further noted that the proposed development site possesses many of the opportunities that NatureScot identifies in relation to landscape character. The SLVIA contends that the following opportunities identified by NatureScot apply to this site: • These stretches of coastline tend to be heavily dominated by the open sea and a sense of vast distance, providing an expansive setting for structures; • In these landscapes, larger structures can be more easily accommodated where they can be set against a backdrop of the sea or where a long stretch of the coastline is relatively straight; • The dominant trend of these landscapes is ‘horizontal’, made up of the horizon, low profiles of adjacent hills, promontories or distant islands which can make it easier to accommodate long, low profiled structures; • The expanse of sea may potentially absorb even very large structures. By locating large structures where there are few – if any – other reference points (except for perhaps the occasional passing ship) the structures will appear small within the larger seascape, when viewed from the land; and • Try to avoid unnecessary clutter and irregular pen sizes or patterns. An ordered pattern of pens and simple feed barge structures will more appropriately reflect the simplicity of the open sea. In terms of the landscape and seascape, the SLVIA notes that although long term in nature, the proposed development would be reversible. Taking account of the above the SLVIA concludes that within the context of the characteristics of the local coastline of a medium to large scale, the receiving landscape and seascape have the capacity to accommodate the proposed development. Having visited the site, officers are of the view that there would be a negative visual impact arising from the proposed fish farm when viewed from a section of the Western Link Footpath. It is particularly the section which runs from Ardailly to Ardlamey, a section of footpath which extends to a distance 4.50km (4.80km in ROH). The SLVIA has determined that visual impacts would be of a large magnitude over a section of footpath extending to 0.98km (1.20km in ROH) where the path is within 650m of the site. There are, however, no designated landscapes in this area which would support the refusal of this application on these grounds. Taking account of the above, on balance, it is not considered that this would constitute a sustainable reason for the refusal of this application due to the short stretch of footpath involved, the low number of walkers that will use it and the lack of landscape designations. Officers therefore consider that the proposal would therefore be in accordance with the aquaculture policies of NPF 4 and LDP2 and also LDP2 Policy 4 and policy 8 which relate to sustainable development and siting.
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Slide 57 - The natural, built and / or historic or archaeological sites and their settings I will now move on to the next criteria listed in LDP2 policy 28. With regard to the Historic Environment the EIAR confirms there are no features of importance within the proposed location. With regard to Scheduled Monuments, the EIAR notes that there are none immediately adjacent to the site, however, the Dun An Trinnse Scheduled Monument, has been identified within the wider area. Following consultation with Historic Environment Scotland, this was scoped out at the EIA scoping stage. In their consultation response to this application, HES have confirmed that a fish farm in this location would not generate setting impacts on the nearby monument at Dun An Trinnse (SM3230). They were also content that the risk of impacts on known marine assets would be minimal. In addition to policy 28 of LDP2 this would also accord with LDP2 policies 15 and 19 and NPF 4 policies 7 and 32. Slide 58 - Designated sites, habitats and species for nature conservation (including Priority Marine Features, wild migratory salmonids and European Protected Species) The proposal is located within the Sound of Gigha Special Protection Area (SPA) which has qualifying interests of great norther diver, red-breasted merganser, eider and Slavonian grebe. As there is potential for likely significant effects on the SPA, Argyll and Bute Council as competent authority is required to undertake a Habitats Regulation Appraisal in the form of an Appropriate Assessment before planning permission can be granted. The AA concludes that subject to the application of mitigation conditions, the proposal would not have a significant impact upon qualifying interests on this SPA. The proposal also has the potential for a likely significant effect on the Ailsa Craig SPA due to potential entrapment and entanglement of gannet. Again, an Appropriate Assessment has been undertaken. The conclusion of this Appropriate Assessment is that the risk of Adverse Effects on Site Integrity can be avoided by the application of planning conditions. The site is also located approximately 5km from the southern boundary of the Inner Hebrides and the Minches SAC, designated for harbour porpoise (Phocoena phocoena). The proposed vessel transit route crosses the southern boundary of the SAC with the potential to regularly interact with cetaceans including harbour porpoise. There is also the potential for direct interactions between harbour porpoise and fish farm infrastructure e.g. entanglement in sub-surface netting. 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. NatureScot advise that if the proposal is carried out strictly in adherence to the Vessel Management protocols as set out in the applicant’s VMP (including cetacean protocol), their conclusion is that it will no longer be likely to have a significant effect on the Hebrides and Minches SAC and an Appropriate Assessment will no longer be required.
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NatureScot has advised that the proposal could affect a nationally important population of a protected species, details of which have been submitted in a confidential annex. It is advised that NatureScot would object to the proposal unless it is made subject to conditions so that the works are done strictly in accordance with the mitigation detailed in confidential Annex B. A condition is proposed to require the development to be carried out in accordance with this document. Details of this protected species have been made available to Members on a confidential basis. Taking account of the above, it is considered that the proposal would also accord with LDP2 Policy 73 – Development impact on Habitats, Species and Biodiversity, LDP2 Policy 74 – Development Impact on sites of international importance and LDP2 Policy 4 – Sustainable Development as well as the mainstream aquaculture policies. Slide 59 - EMP Objectives With regard to wild salmonids, the fish farm will be operated in accordance with an Environmental Management Plan until such time as the SEPA regulatory framework takes over. The EMP contains four objectives and details how these will be addressed. This includes measures such as sea lice reporting and compliance, sea lice dispersal analysis, wild fish sea lice monitoring strategy and the implementation of a sea lice management strategy. In addition, SEPA who are due to take on full responsibility for wild fish interactions have advised that they have completed their screening assessment in relation to sea lice for this proposal and their potential impacts on wild salmon. Their screening assessment indicates that one Wild Salmon Protection Zone is influenced by the proposed site namely, Mull of Kintyre – West. The screening assessment output indicates that in terms of a relative contribution to that Wild Salmon Protection Zone, the sea lice exposure risk would not materially change with this farm in operation. Slide 60 - Ecological status of coastal and transitional water bodies and biological carrying capacity (water quality & seabed impacts) SEPA has advised that they have no objections to this proposal and have confirmed that they received an application under the Controlled Activities Regulations (CAR) in April 2023. They were satisfied that the proposed biomass was reasonable within the scope of the new regulatory framework and a permit was issued in August 2023. Subject to compliance with SEPA’s requirements it is considered that the proposal would comply with LDP2 Policy 59 – Water Quality and the Environment. Slide 61 - Commercial and recreational activity (including other coastal/marine users (MOD)), and navigational interests (including anchorages) The proposal has the potential to impact on commercial fishing activity in a number of ways as highlighted in the planning report. The EIAR has considered effect on commercial fisheries. The Clyde Fishermen’s Association (CFA) were consulted on this application and made the point that the data used in the EIAR did not capture boats under 12m. In support of these concerns the CFA submitted a number of fishing tracks which they felt demonstrated that the area is fished and is of significant economic importance to their Members. Whilst these smaller vessels were considered at the outset by the applicant, a further Commercial Fisheries
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Assessment for 12m and under craft was also submitted. This has concluded that the impacts are of negligible overall impact. The applicant has also engaged in further dialogue with the CFA and have agreed to reduce the mooring area by 27% through their Marine Licence application. In response to this the CFA have advised that their stance is to generally not be supportive of new or expanded aquaculture in the area, however, Bakkafrost have made attempts to work with some CFA members to minimise the impact to fishing members in this case in terms of space. Whilst they still have concerns generally and note concern over the need for Sepa testing, they recognise a compromise has been made by Bakkafrost to work with some local fishermen in this area in terms of footprint of the site. Slide 62 - Amenity, arising from operational effects (waste, noise, light and odour) With regard to noise, the development is located along a section of coastline which is relatively devoid of human habitation, with only a few properties to the north of the site having been identified. The closest property is 1.33km from the site as the crow flies. The EIAR concludes that the effects from noise would not be significant, however, a safeguarding condition in relation to noise has also been included at the request of Environmental Health. In relation to lighting it is not considered within the EIAR that there will be any significant effects. In addition to residential properties, the EIAR has also considered the impacts on the Dark Sky Location on Gigha which is 5.65km north east of the proposed development with no direct line of sight. It is, therefore, 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. Slide 63 - Net economic impact, including local community socio-economic benefits such as employment, associated business and supply chain opportunities The EIAR contains a chapter on the socio-economic contribution of the proposal. This concludes that the proposed development has the potential to generate positive social and economic impacts by means of direct economic impact, indirect economic impact (supply chain) impact and induced economic impact. Slide 64 - Potential benefits of sustainable site management proposals, which seek to mitigate or reduce environmental risk from fish farming operations, including escapes, disease and sea lice management and manage risk from fish farming operations, including escapes, disease and sea lice management or manage risk through adaptive management in response to environmental monitoring The applicant has submitted supporting documents which have been attached as appendices to the EIAR. Of particular relevance are the Environmental Management Plan, Sea Lice Management Statement, Fish Mortality Plan, Waste Management Plan, Predator Control Plan, Escapes Contingency Plan and Vessel Management Plan. These all contain details on how the development will be operated and include details of mitigation and monitoring where appropriate. It is considered that the proposal would comply with this element of LDP2 Policy 28.
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Slide 65 - Proposed operational measures which can mitigate or minimise the level of risk of potential impacts (including on other aquatic or coastal interests) Again, in relation to this element of policy 28, a number of documents have been submitted in support of the application which relate to the operation of the site and adherence to these have been attached as conditions. 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. The EIAR notes that marine aquaculture is widely seen as a 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. However, the industry has also been vulnerable to the effects of temperature rises caused by climate change as evidenced by recent fish health challenges. Along with evolving fish health management practices, it is now considered best practice to locate fish farms in more energetic sites. This, however, leaves the farms more vulnerable to the effects of storm events which are increasing as a result of climate change. This issue has been raised by objectors and consultees, however, the Scottish Government Marine Directorate are satisfied with the details of the equipment provided by the applicant. Equipment attestations and specifications have also been provided by the manufacturer which state that the equipment has been designed in accordance with the Norwegian standard to withstand the environmental conditions at the development location. Slide 66 – Site Plan Gigha Community Council has objected to this planning application and their reasons for objecting are summarised in the planning reports. As the community council are here today to contribute to the Hearing process, I do not intend to go into these reasons in any more detail and will leave that to them. With regard to representations, the most up to date situation is that there have been 32 objections and 33 letters of support. The reasons for objection and support are also summarised in the planning reports. In conclusion, the proposals have been assessed against all of the relevant policies of the development plan which comprises NPF4 and the Argyll and Bute LDP2. Subject to conditions, it is considered that the proposal would comply with these plans. It is therefore recommended that planning permission be approved subject to the conditions contained within the Report of Handling. APPLICANT The Applicant made their presentation with the aid of power point slides. Ian Laister Ian Laister advised that he was the Managing Director of Bakkafrost Scotland and that he was accompanied by Craig Johnstone, who would talk about the team that live and work on Gigha, and Freddie Parffrey, who would talk about the technical elements of the development.
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Mr Laister talked about their overarching business and strategy and what they were trying to achieve across their entire operation in transforming fish farming across Scotland. He advised that Bakkafrost was an international fish farming group with operations in Scotland and The Faroe Islands that dated back over 40 years. Salmon farming was their business and heritage and all that they did. As a business in Scotland 5 years ago they were acquired by Bakkafrost which came with a vision and strategy to transform salmon farming and not just their business. He referred to how they fitted into the global food supply chains. There were estimates that population growths would reach almost 10 billion within the next 20 odd years. The estimates for the resources and food requirements were estimated to be the equivalent of 3 times the total natural resources that the earth provided. Salmon, as an animal protein, was the single most efficient form of animal protein produced globally across all forms – lowest carbon footprint, lowest land use, lowest feed conversion, lowest water footprint and highest edible yield. Salmon was the UK’s number 1 export globally in food. He advised that the industry contributed in excess of £760m gross value add to the Scottish economy, provided employment in coastal, rural and island communities (2,500 direct jobs with a further 10,000 in the supply chain with over 3,600 Scottish suppliers). Bakkafrost were a key part of working and living in these rural locations. Salmon was known as ‘King of the Fish’, its life cycle was 2 to 3 years and the survival rate of wild salmon ranged from 2.5 to 6% in terms of return for spawning. From a farming perspective, there was a representation in density of how farming looked in terms of its production. The entire industry in Scotland, 200+ farms, represented around 50% of the land area that Edinburgh airport represented. At maximum biomass within a cage, the density was around 2%. For this particular application, at maximum biomass at the point of harvest, the density was around 1.2 to 1.3%. Their business was based from the Western Isles at Loch Roag down to Arran in the south. They were an island and coastal based business. They had a head office in Edinburgh but 90% of staff lived and worked in the areas they farmed. He advised of the company’s set of values which was imbedded into all that they did – in operations, investment decisions, and how they did business on a day to day basis. He referred to their 5 pillars of sustainability – • a healthy business (need to be a profitable business to be able to invest in the long term with scale and efficiency of production – this development represented a step on that journey to enhance those aspects of the business). • healthy salmon (the best welfare practices that included density, husbandry practices and all aspects of rearing the fish), • healthy people (need good and skilled people – that comes with training. People that lived and worked in the areas where they farm. Need to give them opportunities to progress and also stay in the area that they lived and worked. As an industry they paid on average 10 to 15% above the national average wage), • healthy environment (fundamentally consider their impact on the environment in all they do and are seeking to improve that). As a business they have moved to be 100% compliant in terms of regulatory environmental checks across all their plans in the last
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5 years. They believed they were the only producer in Scotland that has achieved that. • healthy communities (they live and work in the communities in which they farm). They believed they were an integral part of these communities and the future of these communities, giving high, well paid, long term, secure jobs as well as supporting the wider community in terms of the supply chain and their investment in those areas. As an overarching strategy, their strategy was driven by animal welfare, fish health and survivability at its forefront. Broadly a fish life cycle was around 36 months (one year on land and two years in sea). Fish were put into the marine environment at juvenile stage at 100g – 150g currently across Scotland and spent up to 22 months in the sea. That meant they spent two summers there. In Scotland, over the last couple of years, the industry has experienced over the summer what was called the El Niño events – a global phenomenon affecting mostly the Atlantic up to Norway. It has had a significant impact in terms of some of the challenges that marine animals face, and in particular, this industry. Their strategy as a group which they were implementing in Scotland, was to grow their fish in a healthy, bio secure environment on land, produce strong and robust healthy fish, and put them to sea at 500g. This reduced the marine cycle to around 12 months and took out that second summer of risk from their production cycle. This transformed animal health and transformed survivability. He said they were about to take this step from the end of this quarter forward where they would start to put their smolt to sea at 250g which would reduce the marine cycle down to 15 months. He gave a brief overview of their hatchery at Applecross. An on land based hatchery which produced juvenile smolt for transfer to sea. It was the single largest facility in Scotland in its scale of capacity, production and size. It required a huge amount of power and produced waste. It had a 3 mw solar system on its roof and was connected directly to a hydro scheme and currently, in partnership with the Applecross Trust and a private hydro business, a secondary connection was being built to another hydro scheme with the intent within the next 18 to 24 months, to being 100% direct connection to green energy into this facility. The facility was designed to be highly efficient and bio secure. Its entire basis of design was for animal health. Waste produced was put through a 3 stage process. They achieved the first licence in Scotland for a system called pyrolosis which enabled the waste to be converted into fertilizer. All their smolts that would be stocked in this new site would come from this facility. He also advised of their many technologies used on sea including seal pro nets (first in Scotland to introduce this to all their cages), management of feed through camera based AI based systems to monitor pellets which had helped reduce bethnics. First to introduce fresh water technology for lice treatment and gill disease. He said they had the lowest lice levels in the industry. He referred to the use of hybrid vessels which were highly efficient. Craig Johnstone Craig Johnstone advised that he was the Site Manager on the island of Gigha and that he wanted to give some insight into what they did and how they were an active and integral part of the community. He said that their Community Fund had supported over 155 local community causes since 2017, 51 in Argyll and Bute and 6 on Gigha. This included attending school visits for career events and taking part in wild fishing restoration activities. On the island of Gigha they have supported many local events such as The Sound of Gigha Festival, The Foodies Group, and have also taken part in an interactive workshop with the primary school. They supported the local shop by purchasing everyday
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essentials such as gas and petrol. Their petrol intake allowed the shop to provide for the rest of the island as well, which otherwise would not be possible due to costs. They also supported accommodation on the island with their staff and contractors utilising that throughout the year. They provided a safe haven for local fishermen in the area with their pier and shore base. They have also helped the local Ranger service with beach cleans in remote areas of the island. He advised that they wanted to continue to be active members of the community on Gigha and to not only support the local community, but support their 6 staff who lived there with their families, some of whom were also present at the hearing today. Freddie Parffrey Freddie Parffrey advised that he was an Environmental Officer at Bakkafrost Scotland and also Project Manager for West Gigha. He said that they were confident that West Gigha was the right location. As part of the site selection process they considered a number of aspects, including environmental, socio-economic and logistical factors. He pointed out that the location was in an exposed, high energy marine environment, which would provide inherent fish health and welfare benefits. The location had a very high dispersion potential which would help mitigate environmental impacts, particularly benthic and water quality impacts. The development location was close to their existing infrastructure on the island of Gigha and across Argyll. He said that through using the existing shore base on Gigha they were able to avoid the need for land based development as part of this proposal. He advised that West Gigha was also well placed to supply their harvesting and processing facilities in Argyll. He said there was support and acknowledgement from the Gigha community that their operations played a significant role in economic growth and stability on Gigha, and that they wanted to further contribute to this. He advised that they were confident that West Gigha was the right farm. It would have fewer pens, which would help ensure optimal fish health and welfare and improve operational efficiency. Through the design process they have embedded a number of measures to avoid and reduce potential environmental impacts. The proposed infrastructure has been specifically designed and modelled to withstand observed and extreme environmental conditions. They would make use of remote technologies, such as automated feeding and High Definition camera equipment to carry out inspections, to ensure efficient operations even during poor weather. He said that West Gigha benefitted from various policy and guidance support and, importantly, it accorded with all the relevant policies of the Development Plan. As part of the application process, he said that they had gone above their statutory responsibility and undertook extensive stakeholder engagement to ensure that community views were considered throughout the process. They undertook a comprehensive Environmental impact Assessment (EIA), that was informed by the Argyll and Bute Council Scoping Opinion and Stakeholder feedback. The EIA covered a range of environmental topics. Despite the Council not highlighting lighting as a potentially significant effect, they took the decision to scope lighting into the EIA. This was appreciated by the local community and they received a thank you letter from Dark Skies Gigha.
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He said that whilst an objection was received from Gigha Community Council, they noted that no objections were received from other statutory consultees under the EIA Regulations. He then referred to some of the key environmental topics that were considered through the EIA and gave an outline of the work that they have done to get to this point of the planning application. As part of the design process, they considered the potential for landscape and visual impacts and sought to prevent and reduce impacts at an early stage. They have sited West Gigha in an area that was not a nationally or locally designated seascape or landscape, with NatureScot confirming that West Gigha would not impact upon any nationally important seascapes or landscapes. They have sited West Gigha next to Countryside, as defined in the Argyll and Bute Local Development Plan 2, thus avoiding areas of very high sensitivity such as Remote Countryside Area, and Isolated Coast. They have also sited Gigha in an open and expansive seascape which would help accommodate the pens and feed barge. This aligned with NatureScot guidance on the Siting and Design of Aquaculture in the Landscape. They commissioned a highly experienced consultancy to carry out a detailed Seascape, Landscape and Visual Impact Assessment to ensure that the landscape and visual impacts were fully considered. This assessment was informed by viewpoints from key locations across Gigha. He advised that they also undertook a number of site visits to experience the viewpoints, including those from the Western Link Route. Due to the terrain of these viewpoints and the Western Link Route, they also created a video, in association with the Planning Officers, to allow the Committee Members to experience the Western Link Route. The assessment concluded that the seascape and landscape had the capacity to accommodate West Gigha and the report of handling stated that West Gigha accorded with all relevant landscape and visual policies of the Development Plan. He said that the EIA assessed potential effects on salmonids as a result of sea lice, disease, and genetic introgression as a result of escapes. They undertook detailed sea lice modelling, the ouputs of which indicated that West Gigha would not significantly contribute to sea lice concentrations. SEPA supported this conclusion and stated that West Gigha would not materially change the sea lice exposure risk. He referred to the innovative embedded mitigation that they would implement at West Gigha. Those measures would include the use of high rigidity netting, and mooring system modelling, to mitigate escape events, and their investment in freshwater bathing and FLS vessels to proactively control sea lice. As part of these measures, West Gigha would be managed under the Gigha wide Environmental Management Plan, which included the continued implementation of the Wild Fisheries Sea Lice Monitoring Strategy. Additionally the SEPA CAR licence would be varied by SEPA to implement the Sea Lice Regulatory Framework, which would provide further regulatory protection for salmonids. He advised that the EIA concluded that effects on salmonid populations would be non- significant and the report of handling stated that West Gigha accorded with all relevant nature conservation policies of the Development Plan. He said that from the outset they have sought to minimise interaction with commercial fisheries through the site selection process. They carried out a comprehensive assessment which concluded that West Gigha was not located over unique high value fishing grounds. The assessment identified higher value, more heavily fished areas that
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would not be impacted by West Gigha. However, despite this, they engaged with the Clyde Fishermen’s Association (CFA) and volunteered to reduce the mooring area by 27% to improve access to the waters to the east of West Gigha. This mitigation was accepted by the CFA and showed a willingness to maximise co-existence with other marine users. The report of handling stated that West Gigha fully accorded with all relevant marine use policies of the Development Plan. He then referred to the work they have done in relation to the Sound of Gigha Special Protection Area (SPA), which was designated for great northern diver, common eider, red breasted merganser and Slavonian grebe. They worked with NatureScot and a consultancy to develop a bespoke winter season bird survey, which was carried out by an experienced ornithologist over the winter season of September 2022 to April 2023. These surveys provided valuable information on the distribution and densities of the qualifying features of the SPA. They embedded a number of measures into the design and operation of West Gigha to avoid and reduce potential impacts on the Sound of Gigha SPA. This included the development and commitment to adhere to a bespoke Vessel Management Plan. They undertook a comprehensive Ecological Impact Assessment and shadow Habitats Regulations Appraisal (HRA). These assessments concluded that West Gigha would not result in significant effects on the SPA under the EIA Regulations, nor would it result in Adverse Effect on Site Integrity under the Habitat Regulations. NatureScot agreed that West Gigha would not significantly affect the Sound of Gigha SPA and the report of handling stated that West Gigha fully accorded with all relevant nature conservation policies of the Development Plan. In relation to the Inner Hebrides and the Minches Special Area of Conservation (SAC), designated for harbour porpoises, they have embedded a number of measures to avoid and reduce potential impacts. This included the use of correctly tensioned high rigidity netting, the commitment to not use Acoustic Deterrent Devices and secondary anti- predator netting, as well as the commitment to adhere to the site specific Vessel Management Plan. In relation to the northern gannet qualifying feature of the Ailsa Craig SPA, he said that they also embedded a number of measures, including full adherence to the NatureScot guidance on the use of pole mounted top nets, including mesh size requirements, as well as monitoring and reporting requirements. NatureScot agreed with the conclusions of the EIA and the shadow HRA and stated that West Gigha would not significantly affect either of these European Sites. The report of handling stated that West Gigha fully accorded with all relevant nature conservation policies of the Development Plan. He advised of salmon farming being a vitally important component of the Scottish economy. In terms of their contribution, he said that in Scotland they employed 391 FTE members of staff and spent on average £141 million across 640 Scottish based suppliers. At a regional level, across Argyll and Bute, they employed 181 FTE staff and paid a total annual wage bill of £6.3 million. They also spent on average £14 million across 78 Argyll based suppliers. At a local level on Gigha, they employed 7 full time staff members, 6 of whom lived on Gigha. On average they also spent £34,000 a year with Gigha based suppliers. Through Direct contributions, West Gigha would provide a direct GVA (Gross Value Added) of over £600,000 and create 5 full time, well paid, and highly skilled jobs.
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Through Indirect contributions, West Gigha would generate supply chain activity through an initial set up cost of £8 million. It would also generate an indirect GVA of £424,000 through supply chain activity and create 5 full time jobs within the aquaculture supply chain. Annual spend with Gigha based suppliers would increase as a result of West Gigha gaining approval. Through induced contributions West Gigha would generate an induced GVA of over £121,000 and create one full time job within the wider Scottish economy. The EIA concluded that West Gigha would result in significant positive socio-economic effects. The report of handling also stated that West Gigha fully accorded with all relevant socio- economic polices of the Development Plan. In summary, he advised that there was national level support for the sustainable development of salmon farming in Scotland. As a company they were investing in their future in Scotland and West Gigha was an important part of their sustainable development plan. They undertook a comprehensive EIA which concluded that West Gigha was within the assimilative capacity of the receiving environment. Through the design process and EIA process they embedded measures to avoid and reduce potential impacts at an early stage, helping to ensure sustainable operations. They were a significant component of Argyll and Bute’s economy, and they provided well paid, and highly skilled jobs to the people of Argyll, and they were an active member within their communities. West Gigha would be an important part of this contribution. He said that West Gigha fully accorded with all the relevant policies of the Development Plan as well as Scotland’s National Marine Plan. Through a comprehensive, evidence based assessment, Argyll and Bute Council recommended within their report of handling that West Gigha should be granted planning permission. He asked that the Committee approve this application and help them sustainably grow salmon farming in Argyll and Bute. CONSULTEES Gigha Community Council Tony Philpin gave the following presentation: I live on the west coast of the Island, where there are only three dwellings. I am also a Community Councillor on the island of Gigha. I worked on the two existing fish farms for several years, and am very familiar with their working practices. I hold a DOT Yachtmaster Ocean ticket and have over 20,000 sea miles, so am an experienced mariner and skippered professionally. I have a Geography degree and taught both this and Environmental Sciences up to Higher level. The island’s west side is virtually undeveloped, and that is a key element in the current Local Plan. Under existing development policies no land based development is permitted on the remote west side of the island, yet we now have to consider a proposal for a very large industrial marine development immediately adjacent to the island’s pristine and remote west coast, which has very high scenic value.
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The Community Council surveyed 99 occupied households with 83 responses. 61% of these were against the development and 39% in favour. The results are statistically representative of the opinions expressed by islanders. I note Bakkafrost have questioned this survey, so I’ll add that I studied social statistics at University, and have been involved in large social attitude surveys. I am entirely satisfied with both methodology and results reporting of this survey. The main support for the proposal from the 39% islanders in favour is on the grounds of creating new permanent jobs for full time islanders. The company suggests an additional 5 FTEs may be required to cover the additional labour requirements with its 3000 tonne production limit. Additionally, the local shop feel their trade would receive an advantage from having more fish farm operatives working from the islands Bakkafrost shore base. Currently, around 6 people living on the island work on the existing fish farms, though during fallow periods staff are often redeployed to other aquaculture sites on the mainland. During much of the fish farming cycle, workers are brought over daily from Tayinloan on the mainland directly to site in the fish farm launch. This situation wouldprobably be much expanded with a third fish farm site on the island. Unfortunately, it is very unlikely that another 5 FTE jobs would benefit the island directly because our island demographic just does not match the employment profile for aquaculture recruitment, however mainland Kintyre may well profit from any new job opportunities. There are 5 new two bed dwellings currently being built at a cost of almost £400,000 per unit. The Trust undertook this development after their own survey of unmet demand. Reportedly, these new units are oversubscribed, but will be fully occupied anyway long before any new fish farm employees are recruited. There is a very restricted potential for the islands housing stock to absorb new Gigha fish farm workers. There are also resource implications for services like water, electricity and broadband. The planned location for the new fish farm is over 9km from the Bakkafrost land base by sea, roughly 30-40 minutes travel in calm conditions. There will be a new permanent concrete barge on site which will stock food and other aquaculture resources, and on which staff will be based. The proposed location on a highly unprotected lee shore, fully exposed to Atlantic gales and storms and is the most exposed location on the island. Local objectors expressed concerns on several grounds in the Community Council survey. Landscape The fact that a very large marine industrial unit will be placed in an undeveloped, isolated and pristine coast and seascape was the main concern for many. Even on Gigha, there are few truly isolated sections of coastline.
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That the proposed fish farm would be developed within our highest, most dramatic cliff lines is seen as having a seriously adverse impact, reducing landscape quality and sense of remoteness enjoyed by locals and visitors alike. Islanders are very well aware of other Hebridean locations where new fish farm developments have been rejected on the grounds of landscape quality and despoliation of remote and isolated coastlines. A number of objectors felt this also must apply to the west Gigha proposal. This may be qualified as islanders feel that expansion of fish farms on the north east coastline of Gigha is more logical and would be acceptable, especially given the extremely difficult logistics for daily access to the west. Pollution Risks I lived just 250 metres from the East Tarbert Bay fish farm for 12 years. In my experience, there are extended periods of considerable operational noise and long periods of 24/7 floodlighting, more so in recent years as increased management problems and present of well boats, which very often work 24 hours continuously. Light pollution from barges, cages and work boats may well compromise Gigha’s dark skies status and affect visitors. Noise pollution is a periodic but very prominent impact of high intensity works on sites, and even the feeding cycle is noticeable in quiet periods. Effluent was noted as a major concern. Several thousand tonnes of waste per cycle would be dumped into the currently unpolluted waters to the west of Gigha. Fish waste sinks and accumulates below the cages so fallow periods on the existing fish farms are essential between cycles to allow this to break down and disperse. As colder waters hold higher oxygen levels, warming waters mean slower breakdown so dispersal has become more of a concern in recent years. Fallow periods have already had to be extended due to warming waters, higher disease levels and greater biohazards. Our very low tidal range means low levels of dispersion with tidal streams being under 0.5km for most of the tidal cycle. This is already seriously affecting existing fisheries, but a new development in pristine waters with low dispersal carries a higher but unknown risk level of contamination. Hazardous operations The third set of objections on accident risks result from the very unprotected location from this the proposal. The intended site is probably the most exposed location of a fish farm in Scotland. At the proposed site the cages directly obstruct normal coastal passages, so any marine movements are across the site, and require more attention.
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There is a much higher risk of navigation errors and collisions as the direct line for recreational traffic is through the proposed location. Commercial fishing boats tend to trawl parallel to the coast. Absence of the required fixed navigation lights at night has been a frequent problem at the two east side fish farms, sometimes for extended period. This increases risk levels. The 150 metre diameter cages proposed are untested and untried by Bakkafrost, and islander concerns have been expressed that accident risk levels will be amplified. On exposed sites there is a higher risk of equipment failure. Even relatively small problems will be aggravated in this location through difficulties of access, exposure, and be vulnerable in rough sea states. On Gigha we experience ‘rough’ or ‘very rough’ sea states for days, even weeks, during our winters. Our average wind speed for 5 months a year is 14 knots or more. This means a wave height of over 2 metres for extended periods further amplified by winder over tide. Even a frequent maintenance issue like servicing a fish farm feeder becomes exceptionally difficult in such conditions, and the risk of accidents is very high. What happens if there is a build-up of tonnes of morts in such large cages for several days or even weeks? What happens if there is a two week period of gales and storms, and the barge cannot be restocked with fish feed? What happens if stressed ground tackle is unable to be replaced? It would only take one or two shackles to break for there to be a cage failure in such an exposed location. When the accident happened at Carradale there was an escape of 30,000 fish. Some were then detected in Cumbria, over 100 miles south, less than a month afterwards. On the west side of Gigha, any escape from the massive cages is likely to have catastrophic impacts on wild salmon up the entire west coast of Scotland. Biohazards in handling morts are a very serious concern. The CEO of Bakkafrost gave a recent interview on increased mortality and commented that several of their sites had over 40% mortality through the last cycle. The Scottish average is 23%, so almost one tonne of fish dies for every four eventually harvested and has to be disposed of during the production cycle. This is largely due to increasing water temperatures due to climate change. Three years ago the east Gigha fish farms lost over 80% of fish in a single production cycle. For a west coast fish farm, at the current 23% loss, a new farm will need to remove and dispose of some 750 tonnes of dead fish every cycle. That is well over one tonne a day. A bad season at 40% would mean removing around 1400 tonnes of dead fish, and an extreme 80% such as occurred at Gigha would kill over 2500 tonnes of fish. The current mortality management plan is very vague but basically proposes that morts will be transported to the land base and then removed from Gigha by lorry. With a plan to increase silo storage of morts at the land base for onward transport. However, Calmac
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are about to reduce commercial vehicle sizes on the ferry due to loading concerns on the ramps. This means a reduced capacity per vehicle, and so removing say 1000 tonnes of dead fish could need an additional 20 lorry loads – quite a concern. Logistics, especially in our 5 poor weather months, will present very considerable difficulties, high biohazard risks at several stages from the removal of morts from the site, transferring them to the shore base 9km away, and then removing them in lorry transport on the Gigha ferry. I’ll conclude with a brief personal overview. I’m a very strong supporter of sustainable aquaculture, and Gigha has benefitted enormously over the years from our fish farms. However, the proposed highly exposed site, far from its land base, open to full Atlantic storms for five months a year, is one of the worst possible locations for a fish farm in Scottish waters, and not just in landscape terms. It has huge potential for accidents and even major fish escapes, especially given the experimental use of unproven cages. Whatever the theoretical engineering of these installations, in the real world there will be failures, there always is. I am especially concerned at the considerable weakness in the mortality handling proposals, which I don’t think are fit for purpose. Developing this location would be an accident waiting to happen. Bakkafrost need to seek a different, more sheltered location for their expansion plans on the eastern side. This would then be able to secure majority support from us islanders. SUPPORTERS Audrey Dickie Audrey Dickie gave the following presentation: Good morning My name is Audrey Dickie. I have lived on Gigha for the last 20 years, though my connection to the island stretches back more than 50 years. I am a housewife and I also work for the Royal Mail. I am not here to speak regarding the environmental impact of fish farming however I can speak to the social impact on Gigha. Over countless years Gigha’s main industries were farming and fishing. The mid 80s saw the embryonic creation of fish farming brought to Gigha. Between the 80s and 90s two fish farm sites were created, one land site and one cage site. Both sites together employed approximately 10 full time employees, all residents on Gigha. Fish farming became a well-established industry and much needed employer for the island. Fish farming has been established on the Gigha now for almost 40 years – it is not a new industry, but it is an essential one. For many decades the islanders of Gigha lived under private ownership. The island saw a succession of landlords come and go over those years. By 2001, Gigha’s population was in decline with only 96 people living on the island and 6 children enrolled at the school.
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Many young people left the island to obtain employment and set up home elsewhere. In 2001 the opportunity to reverse Gigha’s fortunes presented itself and in 2002 the islanders were successful in their bid for a community buyout. The buyout in 2002 breathed life back into Gigha once again and opened the door for our younger people to remain and live on the island, with housing becoming available to them. All through this time, fish farming remained constant, essential employment to the island and the islanders. At the end of last year, a survey was undertaken by Gigha Community Council with regards to the Bakkafrost proposal we are discussing today. It is interesting to note that there are other major developments which have been undertaken, are currently being undertaken, and are proposed to be undertaken on Gigha (the building of five new houses, the creation of a MUGA – Multi Use Games Area, the building of a campsite to name but a few), all of which have had, or will have, an impact on the community. However, as far as I am aware, no survey has been undertaken by the Community Council in relation to any of those developments. Why then has the Community Council decided to carry out a survey only on the fish farm development? Surely to ensure fairness it would seem reasonable if not essential for the Community Council to have carried out surveys in relation to the other major commercial developments – and not assume that the community were in approval of same. Further, it states in the Community Council summary to their survey, submitted to Argyll and Bute Council in November 2023, “we received 83 responses. 61% of respondents were against the proposed new fish farm and 39% of them were in favour.” What it does not state is whether these were individual responses or household responses. Initially when the survey was being undertaken it was circulated as one survey per household – however some time during the period of the survey I believe this criteria was amended to being a survey per person, not per household. And so, it is unclear as to how the percentages have been calculated – is it per person or per household? Under the section marked “Conclusion” of the Community Council’s Summary it states “Gigha Community Council therefore objects to the proposed application on behalf of the majority view expressed by the community and believes that this proposal should be refused”. There were 83 responses to the Community Council survey – 61% which is equivalent to 50.63 responses were in objection and 39% or 32.37 responses were in favour. 61% however does not equate to the “majority view” expressed by the whole community. What it does represent is the percentage view in relation to responses received to the survey. There are currently approximately156 adults living on Gigha. If the same formula was to be used for objections – 61% of 156 would equate to 95.16 responses. Quite a difference to 50.63. The survey, in my opinion is therefore not a clear, fair, or truly indicative view of the whole of the community of Gigha – it is merely a representation of the view of the respondents to the survey not the view of the community as a whole. In order to ensure transparency and clarity, the vehicle for individuals to approve or object to planning proposals in Argyll and Bute or any other Council area is obviously through the Council Planning department. There were, as of 11 November 2024, 33 people in support of the fish farm and 49 objections. If you break down those figures further, to purely look at the number of people in support or objection to the project, who currently not only live on Gigha, but who also
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lived on the island permanently at the time of the buyout, you would find of the supporters, 12 currently live on Gigha and lived on Gigha at the time of the buyout yet of the objectors, only 1 currently lives on Gigha and lived on Gigha at the time of the buyout. The Community Buyout and those who lived on Gigha at the time of the buyout, gave opportunity to so many new people to come and have a future on Gigha, something that we should all be thankful for. Opportunity may not have been available for new people to come and live on Gigha had the buyout not taken place. Of the 6 current staff that work at the fish farm site at Highfield at least 3 of the boys were residents on Gigha at the time of the buyout and continue to reside on Gigha. The fish farm has provided them with employment opportunities to allow them to remain on Gigha with good jobs affording them the opportunity to build their future on the island. All the current staff contribute to the economics of Gigha. They live in rented accommodation on Gigha, they use the local shop, they attend social functions and fundraisers, they use the local pub and Boathouse. Bakkafrost have been supportive of local groups on the island including the school in relation to swimming lessons for the children, the summer fayre and the Gigha Foodies Group to name a few. This all feeds and helps to sustain the local Gigha economy. The fish farm has also given the opportunity for new families to move to Gigha. In turn this has helped with numbers for our local school. Without employment at the fish farm, these men would need to leave Gigha to find employment. This in turn would have a detrimental effect on the community both socially and economically. The new fish farm may give rise to new employment opportunities. If nothing else, it will allow the existing workers to enjoy a secure future on Gigha. With the recent closure of the halibut farm on Gigha and the temporary closure of the hotel, Gigha now, more than ever, needs investment and employment opportunities. There is not the luxury of companies queuing up at the door to invest their own money and provide necessary employment and opportunity to Gigha residents. To finish up I would like to quote the wise words of one of the supporters for the fish farm development, William McSporran MBE who has lived and worked on Gigha all his life – “I am 87 years of age, born and bred on Gigha and lived all of my life on the island. I have lived through many changes on the island. To ensure that others have the privilege of living their lives in our small community, we must embrace change and development which secures jobs and economic benefit to the island.” I would ask that the Council give their consent to this proposal. Thank you. OBJECTORS Tony Philpin Tony Philpin advised that given he had covered the summary of the Community Council survey and detailed some of the objections and given a brief personal conclusion to that about the issues of trying to develop on an extremely exposed site, he did not think he needed to say any more.
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MEMBERS’ QUESTIONS Councillor Irvine asked the Applicant to provide some context around discussion on the siting of the site in a rough part of the sea and give reasons why that site was chosen rather than more sheltered sites. He also asked for comment on perceived risks of rough weather off the west coast of Gigha. Ian Laister said that this industry was around 50 years old and has moved at an incredible pace. As referred to in his opening statement, he said that their mission and journey was about wholesale transformation of an industry. Their parent company was around a decade ahead of them in Scotland in its transformation. Most of the solutions that they were looking at in Scotland have been applied in an area that was more than 200 miles north of the north of Scotland. It was in the open Atlantic. So, in terms of exposure and rough areas, they were experts as a business. The suppliers that they used to support them in the specification of materials were international suppliers, working in very exposed areas, in multiple regions including Norway. He said it was important not to look back to what the history used to be, at what the risks were and whether they could be surmounted. There was vast knowledge and capability across an international sphere of suppliers in areas which were much more exposed than this. He said he was talking about the highest specification of equipment for this area. As a business, on a wider basis, he said they were not finished with their transformational journey. Looking at where they were now, compared to when the gentlemen from the Community Council worked in the industry, he said they were not the same business. They were not the same industry. Every single aspect of their infrastructure has been unscaled – scale of their boat fleet, specification of equipment and the quality of the equipment used and husbandry practices. He said there was virtually nothing in their internal business that was done the same way as it was 5 years ago. Their equipment was not of the same scale. For example, they had a boat that could deal with mortalities, an oil rig supply vessel that has been converted, and that boat previously worked out in the North Sea. He said the specification of their assets and equipment was well within the specification of the area being talked about. Freddie Parffrey advised that for West Gigha itself a current meter was placed at the location for 90 days to get an understanding of the current dynamics there at the surface, middle of the water and the sea bed. The characteristics aligned very well with the SEPA Regulatory Framework. In terms of current, speeds, velocity and direction, it lent itself really well to salmon farming. They also undertook a wave climate assessment which was done by a really experienced consultancy. The wave plan assessment provided for a 1 in one year storm, 1 in 10 year storm, 1 in 50 year storm, all the way up to 1 in 500 year storm. He said this information would be provided to their manufacturer and they would take this environmental data and model equipment and a mooring system specifically designed for the location. That takes account of the observed environmental conditions and extreme modelled environmental conditions and so builds in a redundancy factor to ensure mooring system can withstand conditions at the development location. Councillor Hardie asked the Supporter what the social impact would be on the island if this application was refused. Audrey Dickie advised that it would have a negative effect as the possibility of 5 new jobs would be lost for Gigha. She said the population had not been exhausted. There were ex fish farm workers who still lived on Gigha, and who may wish to apply for these jobs. There were also people who travelled off the island to jobs in other sites, who may wish to
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come back to live on Gigha, who currently have family who lived on Gigha. She advised that she thought that if it was refused it may cause an impact socially to Gigha. Councillor Brown asked what the mortality rate currently was. Ian Laister advised that the industry mortality rate ranges by year. In the last couple of years due to El Niño event it has been higher. This year it has returned, to what he would call, historical levels. He suggested that from a company perspective for this application, history was not representative of what was being talking about in respect of this application. He referred to starting their transformational journey and said they were just about to make a vast difference. He advised they were moving from a position where their fish were produced in non-bio secure facilities before they were transferred to sea and then spent 2 years including 2 summers, to a position where they were now reared in a facility that was fundamentally driven by animal health. They were transferred to sea at a much larger weight and spent one summer in the sea. He said the current industry average was around 25% but that was based on the historical practices. The next stocking of Gigha would be on a completely different model and from next year they would be leading in the industry by putting fish in the sea that were almost twice the average weight of their peers and that would be all fish to sea starting in late this year onwards. He said that their mortality rates currently were in line with the national average and they had models to suggest what the mortality rate would be in a second summer, but their fish would not be in the sea for a second summer. Councillor Brown sought clarification on the use of the pens in the sea. She asked if the use would be less as the fish would not be there for a second summer. She asked if that would mean a cage would be left fallow for the extra summer or would there be more smolts coming in. Ian Laister said that in terms of moving forward, on a 500g smolt the marine period was around 12 months plus 2 months fallow. On a 250g smolt, which he said was where they would be in the next few months , the marine period was 15 months plus 2 months fallow before restocking. He said restocking would happen more regularly and the fallow period would be the same. Councillor Blair referred to Gigha Community Council advising that they would be supportive of development on the east side of Gigha, and asked why they were against development on the west side. Tony Philpin explained that the east coast of the Sound of Gigha was a sheltered shore and did not have big cliff lines. He said that on the west side there was a cliff line 50m high and several km long that, if it was in England or Wales, would be part of a coastal National Park. He said the cliff line was stunning in landscape terms and the area was completely undeveloped. He said that LDP2 has the principle that the west side of Gigha, the exposed Atlantic side, is undeveloped. He said that if they had the east side developed and the west side undeveloped they had the best of both worlds. He advised that if both sides were developed there would be a loss of landscape quality. He said this new proposed farm would be very visible. He said it was not simply visibility that reduced the environmental quality, it was the fact that it was there at all. He said there was a Recreational Opportunity Spectrum which worked on the proximity to no manmade features and the presence of a man made feature in the landscape reduces landscape quality in wilderness terms and in people’s perceptions. He said this ROS went back 50 or 60 years in terms of National Park development in the UK, including the Cairngorm.
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Councillor Blair asked the Gigha Community Council if they had done any assessment of the number of visitors to that side. Tony Philpin advised that as he lived next to the path he would say they probably had about 1,000 people per year using the western path. He said possibly several hundred kayakers. He said it was difficult to tell how many yachts as some of them came quite close in. He said it depended on the wind direction on the course they were taking down the Sound. He advised that in terms of commercial vessels, they usually had 3 or 4 a week, possibly more. He said if the wind direction was coming from the east or south east the trawl boats would be on the west side as that would be the only place that had shelter. He advised that if the wind was blowing from the west then they went on the east side. He thought that roughly a 1,000 people per year in terms of the west coast path itself, and probably at least double that in terms of going up to the viewpoint, the trig point at the highest point on the island. He said that the loss of visual amenity was only part of the equation when looking at putting a new development in an undeveloped landscape. He pointed out that the east side was already developed, the quality of the coastline was quite different and it was accepted. There were already 3 fish farms on the east side, the land site plus the 2 cage sites. He said there would be no new additional loss of landscape quality from amending or expanding a fish farm there, even if it went further out into the Sound of Gigha where there would be stronger currents. Councillor Blair asked the Applicant about their process of removing dead fish. Ian Laister advised that they had not quite completed their transformational journey, but by the time of the next stocking of their existing sites has happened they will have implemented their new sustainability strategy for fallen stock. He said that they had shore based facilities where they could stabilise the material and by being kept stable they could have it treated in a certain way. He referred to previously mentioning that they had a very large vessel that was capable of operating in all weathers and all conditions, which would provide support if there was an event driven by environmental factors. In terms of what then happens to the material once stabilised, he said they had a partnership with a company in the central belt where the material was taken and processed into either bio diesel or fertiliser. At this point the Chair ruled and the Committee agreed to adjourn the meeting at 12.30 pm for lunch. The Committee reconvened at 1.15 pm with all those present confirmed as in attendance with the exception of Councillor Dougie Philand who had to leave to attend another meeting. MEMBERS’ QUESTIONS (CONTINUED) Councillor Blair asked the Applicant what they did in terms of training staff to ensure they had the highest quality of skills. He asked if there were any continuous and ongoing assessments undertaken in terms of operating the equipment used. Zane Pretorius advised that they had a massive training programme for all staff. He said they had a lot of legal training that was required all the time and any time new equipment was introduced the staff were trained on the operation of that. Once the equipment was on site they repeated processes that many times that everyone became well accustomed to it. He said that they had a full induction programme for new staff and they had lots of sites that they could train them on. All of the legally mandated training was accredited by
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the MCA in boat use etc. In terms of using the equipment, the manufacturers were the ones that generally came out to train staff. Councillor Armour asked the Applicant if they had given any consideration to enhancing the sites on the other side of the island or in a new area that would not find it as difficult in a prevailing wind west. Ian Laister said he had covered that they believed this site was safe and accessible and they had the appropriate level of trained staff and capability in vessels to access it. He advised that they had extensive remote technology now. For example, fish monitoring and fish feeding was done remotely. The reason for the size of the barge was so they could hold an extended period of feed on the barge and manage that remotely Freddie Parffrey advised that in terms of the location, there was a lot of policy support and guidance that was guiding aquaculture towards these more exposed locations. He said that they have done a lot of work in terms of what equipment they were going to put there that could deal with the environmental conditions. The manufacturer that will be delivering this equipment have delivered equipment to locations that were far more exposed and less secure and they were confident that West Gigha was well within the range of what their equipment could do. He advised that they had no concerns in that respect. Councillor Armour asked the Applicant whether they considered using the site they already had and enhancing it, or a site on the other side of the island. Ian Laister said there was a direction in the industry globally, and it was absolute in Scotland, to larger, more exposed sites. He advised that in terms of the sites on the eastern side of the island in their long strategy, they would look to see if they were appropriately positioned. As a long-term strategy they were looking at that across all their current farming operations, including on the east side of Gigha. He advised that new consent brought with it new productive capacity. Changing an existing site would mean upgrading the entirety of very expensive infrastructure which, he said, they did have in their plans. He said that was in their 5 – 10 year plan rather than 0 – 5 year plan. Councillor Armour asked the Applicant if they would be confident of reaching that site if a major incident in extreme weather was to occur, for example, cages were broken up leading to fish escapes. Ian Laister advised of reference made that these would be new untested cages. He said this was wrong. He advised that their parent Company routinely installed160m and 200m cages. In Norway the standard was 200m cages, so this was not new technology. He said they were designed for extreme locations. The design of the moorings were for extreme locations. He said there were very few instances globally where such an event would lead to the break up or dislodgement of a farm. He referred to mention of Carradale, and advised that was a specific issue due to an incorrectly installed grid, which had mooring cables across another, which led to abrasion and breakage. He said it was due to a faulty installation and not a faulty design. He stressed that they would never put people at risk. He said that they believed they had the capacity and capability and that they have invested very heavily in that. They had vessels that were capable of operating in all the conditions that they experienced. They already had a number of very exposed sites out on Benbecula and in Loch Roag on the north of Lewis. He advised that they have been upgrading all their infrastructure and that they had work boats capable of operating in this weather and very large support vessels, including their ex off shore oil
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support vessel that could operate in all weathers. He said that, obviously, he could not answer that in every scenario as they would never put people at risk. Councillor Armour sought and received an explanation from Gigha Community Council on the process they undertook to survey the island and collate responses. Marion Stevenson explained that initially the survey was issued to all 99 of the inhabited properties on the island. It was paper based in order to check that everyone that responded lived on Gigha. Initially it was one form per household but people had asked what they should do if there were differing views within a household. Therefore, with as much publicity as possible, people were advised that they could put multiply replies on the forms. She advised that of the 83 replies received, 61% said no and 39% said yes. If the form said it represented 2 adults that was counted as 2. The data was also taken back to one form representing one view and that was the 56 forms. Of the 56 forms there was 34 nos and 24 yeses which came up with a statistic of 61% against and 39% for, which, she said, was identical whether one form was counted as one response or one form was counted as, as many responses as it said. Councillor Armour sought and received clarification from Gigha Community Council that of the 99 forms sent out to each inhabited household on Gigha, that 56 forms were returned with 83 people replying out of around 140. Councillor Brown asked the Applicant about the treatment of fish to help with sea lice. She commented that she had read that wrasse did not like fresh water and asked if they were a casualty of their cleaning methods. Ian Laister advised that 5 years ago they used a combination of lump fish and wrasse. That has now been restricted to wrasse and currently, he believed, that they only now had wrasse at 1 or 2 of their sites across their entire farming sites. He said they were not quite there, but expected in a short period of time that they would not stock wrasse into their sites. Dave Cockerill confirmed that they were using wrasse in far fewer of their sites than they did a few years ago. Largely because they were finding their current methodology of delousing very effective and very welfare friendly for the salmon. It has taken away the necessity, but it was good within lice control programmes to have a variety of tools in the box. He said that they have kept the capability to use wrasse, keeping that skill set alive within staff. With regard to wrasse and fresh water, he advised that when they use wrasse they used a combination of wild caught wrasse and farmed wrasse. Farmed wrasse in tanks occasionally needed treatment for gill parasites and that was done with fresh water, so they did tolerate fresh water. He said it was about the length of time that they were exposed so the time was usually kept quite short. He advised that when they do have farms with wrasse present they did keep the time relatively short. He said that salmon did have more tolerance to fresh water and could benefit from a longer treatment period but if there were wrasse present the treatment was kept short. He advised that there were two things being treated, a gill parasite and sea lice. If it was just a sea lice treatment wrasse did not carry sea lice so a great deal of effort was taken to remove them and ensure they did not go through the fresh water treatment. If the gill disease was being treated, both species carried that so both species suffered from it. Fresh water exposure worked really well in a relatively short period of time to get clearance. He explained that the technology with the fresh water followed by the FLS flushing system was extremely good at removing lice.
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Councillor Brown referred to the removal of waste, which was then turned into fertilizer. She asked the Applicant if there were plans to remove the waste from cages during the fallow time and do the same with it. David Cockerill advised that they had a high degree of compliance currently with their seabed surveys with biological material that ended up on the bed regulated through very strict criteria. This determined whether the amount of biological material was within the environment’s capacity to assimilate and distribute those nutrients appropriately through the food chain or whether there was an excess of nutrients, which might cause an imbalance or dead spots. The question may arise as to whether there was a need to remove such material which was well within the capacity of the natural environment to assimilate and transfer these nutrients to the wider eco system. He advised that in terms of removing waste, there may be technologies in the future but currently he was not aware. Freddie Parffrey advised that in terms of West Gigha, it was a very dispersive site. He referred to the current meter put on the sea bed which stayed there for 90 days and data was collected from that. The near bed water column was very fast moving and had a very high current velocity, which helped disperse the waste. SEPA in their screening report for West Gigha confirmed this and stated that West Gigha would have a very high dispersion potential. So all the waste would be dispersed at very low levels over a wide area. He said that as part of the application process with SEPA they did marine modelling for the site that looked at the dispersion of waste from West Gigha, and the outputs from that indicated very low levels of waste accumulating. He advised that SEPA’s cut off was 250g per metre squared and the marine modelling did not come anywhere close to that figure. He advised that they were very confident that there would not be a high volume of waste accumulating on the seabed. Councillor Green referred to the Applicant mentioning that it was estimated that the world population maybe reaching 10 billion and that salmon being a suitable way of feeding people in a low carbon offensive way. He asked how many of the 10 billion would be able to afford Scottish Salmon. Ian Laister referred to the food chain ranging from low to high quality foods. He advised that part of the reason for their high volume export of Scottish Salmon was due to the high quality of the product. He said they believed it was the best salmon globally. He said their own salmon had a different feed mix content and they produced their own feed to ensure they got that high quality. From a business perspective, they were producing highest quality premium salmon. He said that production resulted in various grades of quality and they sought to maximise the value to be a successful business. Salmon had a route into the food chain from all levels from high quality for premium restaurants into retail ready products. He said that salmon fed into the food chain at all levels but it was a premium product. Councillor Green referred to the Applicant mentioning that the feed barge would be hybrid and asked if there was a particular reason why they could not have a fixed connection to the power grid, which would reduce the impact in terms of carbon emissions and potentially noise. Ian Laister advised that their new specifications for all barges, which included 3 hybrid barges, meant they were all ready for shore power. In rural communities sometimes there was a power restriction. He advised that they did have a programme to look at shore based powering on a number of sites. For expedience and efficiency, he advised that
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they made sure they could cover all bases but they were as sustainable as possible. He said that this, like any other development, would have a medium term plan to seek to connect the 20% that would need to run on generators to be connected to shore power. Penny Hawdon confirmed that this was something they would be looking at going forward. She said there were other considerations to take into account when looking at these connections to make sure licensing regimes were able to facilitate that. She said that it was something that was being looked at across the portfolio going forward. Councillor Green referred to mention of the energetic environment and asked the Applicant what experience they had of damage to the infrastructure due to storms and if there was damage how was that managed in terms of the impact of material washing up on beaches etc. Ian Laister advised that they had regular programmes of beach cleaning and that was reducing in part due to the quality of equipment that was being installed. He said that they were finding on beach cleans they were removing material from other marine users rather than themselves. In terms of storm damage there were various levels. He said they may have a feed pipe that gets broken by movement of water and they have developed cradle systems to minimise that. The most extreme case they experienced was when they lost a barge, which sank. He advised that it was poorly designed and below the specifications of anything they have in the water now. He said that all their new barges were to a completely different specification, which included the highest Norwegian standard, which was the highest globally. He advised that in that case, they went to all efforts, with all relevant authorities to ensure that they created no contamination and, they successfully achieved that at vast expense. Councillor Green asked the Applicant if they changed any aspect of the design to take account of the dark skies status. Freddie Parffrey advised that after an in person engagement on Gigha with the local community where concerns were expressed, they took that into the EIA and fully assessed it and looked at mitigation. Design wise in terms of external lighting when no operations are on site, the only lighting that will be on the farm will be what is required under the Northern Lighthouse Board for navigation. This would be a fixed light on top of the barge which would extend across the horizontals so there would be no light spilling onto the upper sky. There would also be 2 flashing lights on either side of the pens. In terms of operational lighting, lighting will be installed according to best practice, which will be to look at installing it at the highest possible point, keeping the angle of the main beams as acute as possible to stop any light spill. Operationally the standard working hours are from 7 am to 8 pm. There may be times outwith that where work has to be done in terms of fish health welfare but they try to limit activities to within the day time, or early evening or late mornings and not the sensitive night time period. In terms of best practice procedure wise, they look to only light external areas where work is occurring. They don’t want to light redundant areas. Councillor Green referred to the Applicant’s presentation including the benefits to the economy and said that he had noted that just under half of their employees were based in Argyll and Bute but only 10% of supplier spend was here. He asked the Applicant what ways they sought to ensure the benefits to the economy locally were as widespread as possible.
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Ian Laister advised that the expenditure they were undertaking at the minute was at an exceptional level due to their transformation. A huge part of their investment was on the facility at Applecross with 60% of the expenditure on that facility being Scottish and a large proportion local. He explained that a number of suppliers to the industry on specialist equipment were international. There were a number of suppliers in Scotland. Inverness seemed to be a hub and then specialist equipment was varied across Scotland. He said that where they could divert expenditure to local, for example, there was a local joiner on Gigha, and for work on the shore base there this joiner had been used. He said that wherever they could divert expenditure locally in the very vicinity, village, town, they did. He advised that they also maintained as much as they could into Scotland including, for example, they had upgraded a significant number of their work boats. They now had 2 in operation and they were built by McDuff in the north of Scotland and they were currently building a third boat which were £3 million each. He said that wherever they could, they started locally and they spent in Scotland but sometimes they had to go to international supply for specialist equipment. Councillor Green referred to comments made about water temperatures and that they were certain to increase over decades due to climate change. He asked the Applicant if they had evidence to suggest that this would not adversely affect productivity. He asked if they were confident the water temperatures around Scotland would still be suitable to grow salmon for many decades to come. He referred to the company having sites in The Faroes and said he assumed the water temperature around the Faroes was going to remain less than around Scotland. Ian Laister said that from a perspective of operation they have seen, in particular in 2023 and 2022, unseasonably high water temperatures due to the El Niño events. This was felt not just in Scotland but Atlantic wide. This year had seen a return to more normal and historical levels. He said that they believed their strategy off shortening the life cycle of the marine environment and putting much larger, stronger, healthy fish to sea was fundamental in this journey. Also having the right equipment and capability, the right strategy for health, that the water temperatures, which have been experienced are within the animal’s tolerance. Dave Cockerill explained that salmon as a species were extremely adaptable and lived across an extraordinary wide range of climates in the wild. From Spain, to Iceland, to the north of Norway. They as a species had an in built adaptability. He advised that salmon farming also took place across very widely diverse environments. The Australian operation, for example, around Tasmania currently operated at temperatures way higher than what was experienced in Scotland. Parts of Chile had a very wide range, also Newfoundland and Norway. He said that there was a network of farmers and fish health professionals across the planet that regularly got together to share best practice and learn from each other. He thought that climate change would make things more unpredictable in terms of what was currently had would change, but they had examples from around the globes as to how colleagues worked in other climates and environments. He advised that their strategy on gill health was something they learnt from the Australians who have led the way in fresh water bathing. That process would continue and they have identified within their own sites strategies for reducing that risk significantly. He said that they saw the greater challenge to fish health occurred in the second summer with more than 70% of those mortalities then and by removing that second summer the challenge was removed. He said there would be year-to-year fluctuations as with any farming in the natural environment.
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Councillor Green referred to the consultee objector advising of the possibility of mortality events being far higher. He asked the Applicant what the chances were of that happening. Dave Cockerill advised that any mortality that was unusual was something they took extremely seriously. He said you could not predict with absolute certainty that an adverse event may or may not happen. He said it happened in terrestrial farming, if you had an extraordinary cold spring and where there were young, small lambs, there may be a high level of lamb mortality. He thought the same principles applied to both types of farming. He said that they did have an expectation that their strategy would reduce those risks because they were focussing on making sure they did not have small juveniles going into an unpredictable environment. They would have larger, more robust fish going into the environment and they should spend a far shorter period within the marine environment. The expectation was that this would be a successful strategy. Councillor Green asked Planning if there was an assertion that for the west side of Gigha on the land under LDP2 that no developments would be permitted. Peter Bain confirmed that there was no provision within LDP2 that would prohibit development on the west side of the island. The island was generally designated as countryside, which meant there was potential for development provided it could demonstrate to be sustainable. SUMMING UP Planning Peter Bain, Development Manager, summed up as follows: In their consideration of this application Members have been made aware of arguments seeking both to support and oppose not only the proposed development, but also some general debate on the environmental and animal welfare credentials of aquaculture as an industry. In reaching a decision on this application Members should hold in their minds that the planning system exists to balance competing demands and to ensure that land, or in this case the sea, is used and developed in the public’s long-term interest. The effect of planning decisions should be to help increase sustainable economic growth which is the stated main purpose of the Scottish Government. In order to achieve this planning decisions require to strike a fine balance between helping to build a growing economy whilst at the same time providing appropriate protection to the receiving environment and communities. Notwithstanding the ongoing wider debate on the current state and future of salmon farming in Scotland, members should keep in mind that fin fish farming remains a legitimate activity which continues to be promoted by the Scottish Government in recognition of the economic and social value that the industry brings to Scotland through the provision of jobs in rural and island locations, investment and spend within communities, and the stimulation of economic activity both locally and wider afield in its supply chain. Support for sustainable expansion of the aquaculture sector is also recognised and valued by the Council in its Economic Development Action Plan.
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The national debate on aquaculture focuses on the requirement for sustainable development that maintains a balance between fish farming activity and the retention of healthy and functioning marine ecosystems. The Scottish Government identifies that effective and efficient regulation which is informed by the best available science and evidence will support the sustainable development of the aquaculture sector by ensuring that development takes place within environmental limits with due regard to animal health and welfare, wildlife, marine users and communities. Members have today heard from the Applicant that the proposal represents a significant investment in the locality which will give rise to job creation and support for existing employment on Gigha and support for the wider local supply chain economy, including spend within existing businesses located on Gigha. Gigha Community Council and third party objectors have said that the introduction of new aquaculture activity is unsustainable, raising issues about the suitability of the site given its exposed nature; the potential for the development to give rise to adverse impacts upon the natural environment, including nature designations and wild fish interests; the impact of the development upon the sense of remoteness and visual experience of the Western Link Footpath; impacts upon ferry capacity; and potential impacts upon local amenity from operation noise and lighting. Gigha Community Council do however recognise the economic value of the aquaculture industry for the island and would welcome a discussion on alternative locations where there may be greater community support for this type of development. The hearing today has allowed members to hear directly from and seek clarification from Consultees, third parties and the Applicant in respect of concerns raised in relation to the various matters that require to be considered in their decision whether or not to grant planning permission. Suitability of location: Members have heard from the Applicant on their experience elsewhere as a company operating in exposed locations. It is also highlighted that the attestations provided in relation to the suitability of equipment and operational practices have not raised objection from the Scottish Government’s Marine Directorate. Social and economic impact: Members have heard from supporters that the aquaculture industry is considered to be an important source of employment which has supported the growth of the community over an extended period of time. Impact upon landscape and remoteness of west coast of Gigha: The concerns raised by Gigha Community Council and third parties in relation to the impacts upon the west Gigha coast and in particular the experience of the Western Link Footpath have been given careful consideration by Officers. This included identification of shortcomings in the initial submission and submission of updated information to properly inform the decision making process. However, contrary to suggestions made, there is no provision within LDP2 that would expressly prohibit land based development on the west coast of Gigha although there may be other physical and practical factors, including general inaccessibility and availability of infrastructure that might inhibit sustainable development of land in that locality. Officers are in agreement that the proposed new fish farm will have an adverse impact upon local landscape quality and in particular upon a short section of the Western Link Footpath. It must however be recognised that such impacts are very localised and that there are no landscape designations of local or national significance, or designated areas of wild land impacted by the proposal. Whilst this prospectively negative impact has been identified it is not considered to be significant and, on balance is not considered to give rise to sufficient harm to merit that planning permission be withheld.
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In reaching a decision on this application, Members are reminded of the requirements placed upon decision makers by Section 25 of the Town and Country Planning (Scotland) Act 1997 to determine all planning applications in accordance with the provisions of the Development Plan unless material considerations indicate otherwise. In the case of aquaculture development, the key provisions of the Development Plan are set out within Policy 32 of National Planning Framework 4, and Policy 28 of the adopted Argyll and Bute Local Development Plan 2 2024 which set out the relevant criteria to be taken into account in the determination of this application. Notwithstanding the issues raised by Gigha Community Council and third parties, it is the view of Officers that the proposed development is consistent with the requirements of NPF 4 Policy 32 and LDP 2 Policy 28. The current application is also considered to be compliant with all other relevant policies of the Development Plan and there are no other material considerations, including those matters raised by consultees and third parties to indicate that the effects directly attributed to the development upon the receiving environment would be of such significance that they would merit planning permission being withheld. Accordingly, the proposal is commended to Members for approval subject to the conditions and reasons appended to the Report of Handling dated 5 September 2024. Applicant Ian Laister advised that he would like to cover a couple of issues that were raised by other parties. In relation to tourism, yachting and others, there were various assertions put forward that they would like to comment on. He advised that they consulted multiple parties and did quite a wide search in that area as best they could. From a tourism and location of visitors etc on the island they utilised some widely available information of app tracking. That told them that the main areas for visitors and tourists on the island was not on the coastal path nor the area proposed for the fish farm. In relation to leisure and vessels, the Royal Yacht Association was consulted and they confirmed that the farm was not in the path of the normal route of leisure vessels and nor was it anywhere near normal mooring in the area for such vessels which were on the east of the island. They had no material negative consideration of the location of the farm. He said that he thought they had spent a great deal of time talking about how the industry, and, in particular, how their journey was transforming. An industry from what it was 5 years ago, never mind 10 plus when other people may have been involved in the industry. He said that they were not the same business they were 5 years ago. They were transforming an industry. They were putting very significant investment behind transforming their operations. He advised that everything they did was about animal welfare and they were only a successful business if they had healthy fish that grew and survived. It was fundamental in terms of everything that they did. He advised that the other part of the business that they thought was fundamental was that they were farmers, rural farmers, that lived and worked in the locations, which they farmed. He said that Gigha has been part of their business and operation for as long as anyone has worked for their business. They made an active choice for this development to be on the island of Gigha as part of their commitment to such communities. To continue to support communities, for young people to stay and work where they were born. He advised that they saw that as part of how they could help such communities to prosper in the long run. Yet supporting their business model at the same time.
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He referred to talking about some of the risks and said that they were a farmer raising a live animal in the natural environment, and sometimes that was challenging. However, knowledge, including that from other regions, from our parent Company, from medical science, from technology, were all being put to use to mitigate some of those risks. He advised that they contended that this was a beneficial development. It helped support their journey of transforming the industry. They believed it supported the community and that they were committed to this and other rural communities and they commended their proposal for approval. Consultees Gigha Community Council Tony Philpin made the following points: • Faulty installation at Carradale or poor design – he advised that the navigation lights at the existing farms were rarely shown, there were certainly no flashing lights. He said there was plenty of scope for defects in terms of actual operational error and unfortunately it still existed. • Sea temperatures of 17c were now common in June and July regardless of the El Niño effect. • The barge being inshore was certainly helpful but they got a rebound of waves from the cliff, so was not a 100% solution to the problem. • It was not just lice that were the problem. Micro jellies and plankton, which was covered by the CEO of Bakkafrost in his interview in the aquaculture magazine. • As for the population of 10 billion, no it was stabilising at about 8.3 billion at the moment. • As far as the LDP2 goes, he said he was informed that there was basically a presumption against developments on the west of Gigha. They have had suspension of 4 permitted development rights in our own case. • Extreme events – if you have a 1 in 5 storm or 1 in 10 year storm, that did not mean to say they could not occur in consecutive years. He referred to floods on the River Severn for the last 5 years. A 1 in 20 year flood in consecutive years, 3 years running. He said the statistical use of this 1 in 5 year risk, 1 in 10 year risk did not mean anything when it came down to practical experience. Supporters Audrey Dickie said that living on Gigha was a privilege and to enjoy such a privilege, people needed jobs. They did not want to see Gigha’s population go back into decline as it was in 2001 with the loss of this opportunity of employment.
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Objectors Tony Philpin said that his experience of risk was that errors happened regardless of the supposed superiority of equipment and engineering. People made mistakes, they always did. He said he still believed this was a very high risk site and an accident waiting to happen. The Chair established from all those parties that they had received a fair hearing. DEBATE Councillor Jan Brown thanked everyone for their presentations. Having listened to everyone she said she agreed with the planning recommendation to approve this application. Councillor Hardie also thanked everyone for their presentations which, he said, were highly informative. He said the Applicant came across as entirely competent and highly knowledgeable. He thought the social impacts of this development would ensure the future economic growth of the island and so he would have no hesitation in approving this application. Councillor Blair thanked the Community Council and acknowledged that the work of the Community Council was sometimes a thankless task. He said it was important that they had turned up to have their voices heard. He encouraged locals to support their Community Council. He referred to taking the opportunity to visit Gigha to see the site’s location. He said that he was okay with the development and would be happy to support it. Councillor Irvine said it had been valuable to get everyone’s input. He said that this proposal met the requirements for future proofing our food supply. He said he had concerns about the weather but was suitably convinced and comforted by the professionals and their risk assessments. He encouraged the Applicant to continue their good work with the local community and to look at ways to invest and support the community going forward. He confirmed that he would be happy to support the application. Councillor Armour said he found it a shame when a community could not agree about something that would bring jobs and economic development to an area. He advised Mr Philpin that had it not been for his presentation and knowledge of the industry itself, and knowledge of the sea, he would have had no hesitation in even thinking about not supporting this application. But, having weighed up everything, he said that he did feel that, despite his concerns, which he still had about the location, he was going to support the application. Councillor Kain said he would support this application. He commented that he felt there was still a lack of understanding as to the situation regarding trying to reverse population decline and add to the economy of Argyll and Bute as well as the rest of Scotland. He said that it was his view communication between the industry and the community was still not as good as it could be. In many cases this should just be a formality to go through due to the benefits the developments were going to bring to the communities. He said there was still a lack of understanding between the communities and a lack of willingness to communicate directly with the communities in an effort to benefit all.
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Councillor Wallace agreed with colleagues and thought that with the commitments made by the Applicant and the conditions from Officers, as far as possible, the concerns have been mitigated or addressed and that he would be happy to support the application. Councillor Green said he was also minded to support this application. He extended his thanks to all those who had presented today. He said it was also beneficial to hear from Councillor Blair who had visited the site along with Councillor Wallace and it was useful for the other Committee Members to have a video of that in order to gain an appreciation of the view from the path in question. He said that a number of thorough answers had been given to the concerns that had been raised. He commented that it was sometimes an unthankful task to come to a hearing where there was a somewhat divided community as a Community Councillor. He advised that the Community Council were right to raise those concerns and he said he was glad that they had done so. He said it was good that they had received those reassurances. Taking all that on board he confirmed that he was minded to support. DECISION The Committee agreed to grant planning permission subject to the following conditions and reasons: Standard Time Limit Condition (as defined by Regulation) Additional Conditions 1. The development shall be implemented in accordance with the details specified on the application form dated 4/9/23; the Environmental Impact Assessment Report dated August 2023, 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 (as amended). The developer and subsequent operator(s) shall at all times construct and operate the development hereby permitted in accordance with the provisions of the Environmental Impact Assessment Report accompanying the application with mitigation measures adhered to in full, and shall omit no part of the operations provided for by the permission except with the prior written approval of the Planning Authority. Plan Title. Plan Ref. No. Version Date Received Development Location A1 5/9/23 Site Plan as Proposed A1 5/9/23 Barge Mooring Drawing 5/9/23 Feed Barge Elevations and Floor Plans - 5/9/23 Pen elevations and specifications 5/9/23 Pen netting and top netting - 17/10/23
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Admiralty Chart Extract A1 5/9/23 Schematic Diagram A1 5/9/23 Pen Netting Specification 01-1456 5/9/23 Grid Mooring Drawing 5/9/23 Reason: For the purpose of clarity, to ensure that the development is constructed and operated in the manner advanced in the Environmental Impact Assessment Report, upon which the environmental effects of the development have been assessed and determined to be acceptable. 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. Vessel Management Plan The proposal shall be carried out strictly in adherence to the Vessel Management protocols as set out in the applicant’s Vessel Management Plan (including cetacean protocol) (Revision A1, dated December 2022 – 5. Management) or as updated and agreed in writing with the Planning Authority in consultation with NatureScot. Reason: In the interests of nature conservation. 4. Sea Lice Management The development shall be carried out strictly in accordance with the Gigha Environmental Management Plan dated September 2023 version A5 and the confidential Annex 2 dated September 2023 version A2 or as updated and agreed in writing with the Planning Authority in consultation with NatureScot and SEPA. Reason: In the interests of the protection of wild salmonids. 5. 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: Height (m) Perimeter Pole Support Maximum height of 5m above the water surface Mesh Size (mm) Sidewall netting 75 Ceiling net panel and remaining sidewall netting 100 Colour Dark grey to black
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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. 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. 6. Wildlife Recording and Reporting The proposal shall be undertaken strictly in accordance with the following criteriA: a) Operators shall monitor wildlife entanglement / entrapment in both cage and top nets. Top nets shall be monitored daily. Cage nets shall be monitored for entangled birds at least weekly, and preferable more frequently, using camera systems capable of inspecting the entire net surface and / or professional divers; b) The operator shall maintain full records of wildlife entanglement / entrapment monitoring methods and results for both cage and top nets using the standardised NatureScot proforma (https://www.nature.scot/doc/interim-technical-briefing-note- pole-mounted-top-nets-and-birds-finfish-farms) and to submit regular (typically six- monthly) returns of these records to the Planning Authority (PA), copied to NatureScot; c) In the event of any significant entrapment or entanglement in any cage or other nets of great northern divers, gannets, gulls (any species), shags, cormorants or any other single bird species the site operator shall immediately notify both the Planning Authority and NatureScot. Significant should be interpreted as: involving three or more birds on any one day and / or a total of five 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; d) Should and event or events be notified in accordance with the above, the Planning Authority shall agree any mitigation measures required with the applicant in consultation with NatureScot. Thereafter, the agreed measures shall be implemented within timescale to be agreed with the Planning Authority. The identified mitigation shall be retained throughout the life of the fish farm unless otherwise agreed in writing with the Planning Authority. Reason: In order to ensure that there are no significant effects on the qualifying interests of the relevant Special Protection Areas. 7. Predator Control Plan The development shall be carried out in accordance with West Gigha, Isle of Gigha Predator Control Plan dated December 2022 or as updated and agreed in writing with the Planning Authority. Reason: In the interests of nature conservation. 8. Recapture of Escaped Fish - Drift Nets, Vertical Static Nets and Gill Nets
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There shall be no use of drift nets, vertical static nets, or gill nets to recapture escaped fish under any circumstances. In the event of any proposals for recapture NatureScot must be consulted immediately. Reason: In the interests of the conservation of the qualifying species of the Sound of Gigha Special Protection Area. 9. Biodiversity Enhancement Development shall not commence until biodiversity enhancement proposals have been submitted to and approved in writing by the Planning Authority. These shall include details of biodiversity enhancement proposals and shall include a timetable for their implementation. Thereafter these shall be carried out in accordance with these details 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 10. Removal of Equipment In the event that the development or any associated equipment approved by this permission ceases to be in operational use for a period exceeding three years, the equipment shall be wholly removed from the site thereafter, unless otherwise agreed in writing by the Planning Authority. Reason: In the interest of visual amenity and to ensure that redundant development does not sterilise capacity for future development within the same water body. 11. 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 in accordance with the details provided in the EIAR unless otherwise agreed in advance in writing by the planning authority. Reason: In the interest of visual amenity. 12. 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. 13. 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.
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Reason: In order to protect the amenities of the area from noise nuisance. (Reference: Report by Head of Development and Economic Growth dated 5 September 2024, Supplementary Report Number 1 dated 17 September 2024 and Supplementary Report Number 2 dated 12 November 2024, submitted)