Dunstaffnage - Time to Object!

 There's only a few days left to object. here's my effort:

I am writing to object to application number 20/02358/MFF to permit an increase in the overall size of the fish farm at Dunstaffnage. I am a local resident.

Environmental factors.

It has long been recognised that aquaculture should not be carried on in inshore areas, where there is limited tidal flushing and where there are already other sources of pollution from agricultural, domestic and industrial waste. Added to this is the risk of damage to our already fragile populations of wild salmon and sea trout. In this regard I can add little to what Fisheries Management Scotland have said in their extensive submission to you.

In late 2019 there was a catastrophe on the fish farms in mid Argyll. There were simultaneous outbreaks of a highly infectious viral disease, salmon cardiomyopathy, which had been imported to Scotland from Norway some years earlier. Infected fish show virtually no signs of ill health until almost on the point of death, which results from heart failure. As a result the operators were taken by surprise and some farms suffered losses of up to 40% of their stock, invariably of mature fish well on the way to market size. In order to mitigate their losses the operators of most of the farms North from Loch Craignish took the decision to cull the surviving fish early. Below is a table showing comparative mortalities on the current site, with previous data for comparison.

As wild salmon and sea trout are genetically virtually identical to caged salmon we must assume that local populations were similarly devastated. Of course as the wild fish weakened they would have been eaten, leaving no evidence.

In normal times this event would have led to some form of inquiry, but matters were overtaken by lockdown, compounded by the serious damage done by hackers to the SEPA database, which have combined to hamper the operations of our major environmental guardian. It must serve as a stark warning of the dangers of allowing unnaturally large populations of caged fish in the line of the migration routes of wild ones.

The current proposal is part of the rash that has followed the inexplicable failure of the Scottish Parliament to impose a moratorium on fish farm expansion, despite two committees confirming, after the most detailed consideration ever to have taken place, that the existing regulatory system is woefully inadequate. With SEPA disabled, site visits not allowed and everyone working from home, it’s down to our already overworked planners to protect the environment on which everything else depends.

Economic factors

The essential components in the proposal are for the area occupied to increase from 22 to 37 hectares, for the number of cages to increase from 9 to 14 of larger size and perhaps most significant for the automatic feed barge to be changed from a circular unit holding 80 tonnes to a rectangular one holding 300 tonnes. This is a major additional intrusion in an area where, I suggest, there should not be a fish farm in the first place.

As I write this I am reminded that it’s exactly ten years since I became involved in the campaign against the expansion of the fish farm at Armaddy in Seil Sound, in connection with which saveseilsound was formed. I was secretary of the group until it was disbanded following the removal of the fish farm. As we all know, tidal and wave conditions locally at Ardmaddy proved the unsuitability of the site, exactly as the objectors had said they would.

That application attracted over 800 objections, including from a significant proportion of the residents in the area most affected. At the hearing we did our best to present our case, then watched in despair as councillors, none of them from the area, voted unanimously to grant the application. It was notable that Councillor Currie was enthusiastically in favour, despite his home island of Islay having voted in a referendum resoundingly against allowing fish farms there.

This is relevant, because Argyll & Bute does not have a uniform economy, rather our vast area contains a mixture of micro-economies, some more fragile than others. The population of Islay were concerned that fish farms would wreck the livelihood of the local shellfishers, because the poisons used to kill sea lice kill all crustaceans. They were also aware that tourism and leisure were the major components of the private sector, exactly the same factors that prevail in Oban.

From the early Victorian period, when the railways and the steamers first arrived and the major hotels were built, our visitors have wanted to be taken out to see wildlife, to walk along the shores, “Siubhal air na cladaichean 's a' coiseachd air a' ghainmhich” in the words of the song, which contains a clue as to the name of the only beach in the area. Open sea swimming is currently on the increase, with Ganavan the only point of access locally. Currently there is no information available about the adverse effects of the poisons mentioned in the application on human beings. The noise from the diesel generators on the feeding barge, running twenty four hours a day to drive the feeding systems and the underwater lighting that is used at night to deceive the salmon into round the clock feeding, will be highly intrusive.

The fact that the feeding systems are automatic gives a clue as to the direction of employment on fish farms locally. No longer do workers sit in little boxes aboard the barges watching monitors and pouring bags of feed into cages. When lobbying an already supportive government the industry claims the credit for many times the numbers actually directly employed, but even that direct employment is not spread evenly. Manufacture of cages and equipment is carried on elsewhere, as are the major transport businesses and most of the processing and packaging. I suggest that very few jobs will come to the immediate area, against the possibility of job losses in other sectors.

As we enter the second year of the pandemic it is increasingly obvious that there will be a decline in foreign holidays and a corresponding increase in visitors, plus local residents deciding to holiday at home. We should not forget that having an attractive, clean environment is a huge benefit for residents as well as visitors.

We have recently seen Highlands Council responding favourably to these arguments in refusing two applications in their area. I sincerely hope that Argyll & Bute finds the courage to follow suit.