There's a current application to legitimise the smolt growing facility at Loch Tralaig, under reference 21/02612/CLAWU. I have written to our politicians as follows:
Good Morning, MSPs and Councillors
This message concerns a current planning application in respect of Loch Tralaig, a small fresh water loch in mid Argyll near to Kilmelford, where I live, but it raises issues that should concern all of us with an interest in the environment.
In 1991 Kames Fish Farming Limited, then a fairly new company, obtained planning consent to operate smolt growing facilities in three lochs, Tralaig, Losgain Mor and Avich. A copy of the consent for Loch Tralaig is annexed and you will see that it was limited to a period of six years, after which it was envisaged that a further consent might be granted, after an environmental assessment had been made. The same condition appeared in the other consents.
Officials at Argyll & Bute Council failed to notice the expiry of the period in 1997, nor did Kames bring it to their attention. The result was that smolt growing has continued in the three lochs, more or less continuously, for the period to date, thirtyone years. There are indications that cages may even have been in position prior to 1991.
For confirmation of the error I quote from an email I received from the Council in 2020:
“In eventuality, and for reasons I have not been able to establish – all of the involved persons having long left the employment of Argyll and Bute Council – this planning condition was not acted upon when it was first breached in November 1997. In fact, this breach did not come to light until at some point in late 2019 by which time the operations had likely gained ‘immunity’ from any planning enforcement action the Council may have wished to take. Nevertheless, the planning authority took this matter up with the operator of the fish farm as soon as the breach of condition was realised. The subsequent application was made in order to support a claim by Kames Fish Farming Limited that their operations were, by that point in time, lawful.”
Having operated on the three sites for more than ten years Kames had applied in 2020 for a certificate of lawful use in respect of Loch na Losgain Mor. Being fully aware of the position the Council found itself in, basically that in law they had no option but to grant the certificate, I wrote to them asking them to request Kames to agree to carry out the environmental test that they had, after all, agreed to in 1991. The Argyll & Bute planners did not agree to make this simple request and went ahead to grant the consent.
Thus a provision that was designed to enable householders to legitimise things like garden sheds was used to avoid an environmental assessment.
To those of us who know and love these lochs this was a troubling development. I do not fish, but understand anecdotally that none of the three lochs now supports the range and numbers of wild fish that formerly grew there. That would of course have become clear had there been an assessment.
Worse by far was the possibility that in three decades of the constant dropping of fish faeces and uneaten food the loch beds may have become irrecoverably polluted by waste. Two of the lochs, Losgain Mor and Tralaig, feature hydro electric schemes. The former is now privately owned by the landowner, who lives in Cornwall, and is still in use, providing him with no doubt welcome income. I believe the one at Loch Tralaig is, along with part of the alveus and adjoining land, owned by SSE. It is no longer in use, but the dam is still in position, seriously restricting flushing.
Accordingly, in April of last year some concerned friends and I decided to visit Loch Tralaig and carry out an inspection using an underwater camera. The resulting film can be viewed here:
This was filmed near to the edge of one of the cages. You will see that the bed is covered in what appears to be inert, anoxic waste to some depth.
A separate environmental issue is the considerable use of Formaldehyde in recent years. Formaldehyde is a highly toxic chemical with a history of use in disinfection and serious industrial cleaning. It is a carcinogen and industry guidance for its use requires operatives to wear protective clothing. In recent years operators of fish farms have been experimenting with its use in dealing with saprolegnia, a fungal condition which typically affects fish kept in fresh water, such as aquariums and in their case cages in our fresh water lochs, where salmon smolts are grown for eventual transmission into open cages in the sea.
No doubt as a result of industry lobbying the Scottish Environmental Protection Agency decided to allow its use, with companies having an obligation to disclose how much they were using. The figures reported by the various companies operating in Scotland owned up to a total of 22.4 tonnes of poison being poured into ten Scottish fresh water lochs between April and December 2019. I am unable to get detailed, recent figures due to the collapse of the SEPA database but no doubt the applicants will be able to inform you of the quantities used.
In May The Ferret drew attention to the issue in a clear, hard hitting article that can be accessed here:
My purpose in writing is to ask you to write to Argyll & Bute Council quoting reference 21/02612/CLAWU, asking that they consider asking Kames to comply with what they agreed to in 1991, not out of legal obligation, but simply out of the concern that everyone of us should have for our natural environment.
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