Public Document Pack - Argyll and Bute Council

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Public Document Pack - Argyll and Bute Council
Public Document Pack
Argyll and Bute Council
Comhairle Earra Ghaidheal agus Bhoid
Customer Services
Executive Director: Douglas Hendry
Kilmory, Lochgilphead, PA31 8RT
Tel: 01546 602127 Fax: 01546 604435
DX 599700 LOCHGILPHEAD
e.mail –[email protected]
13 March 2013
NOTICE OF MEETING
A meeting of the PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE will be
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD on WEDNESDAY, 20 MARCH
2013 at 11:30 AM, which you are requested to attend.
Douglas Hendry
Executive Director - Customer Services
BUSINESS
1.
APOLOGIES FOR ABSENCE
2.
DECLARATIONS OF INTEREST (IF ANY)
3.
MINUTES
(a)
Planning, Protective Services and Licensing Committee 20 February 2013
(11.30 am) (Pages 1 - 6)
(b)
Planning, Protective Services and Licensing Committee 20 February 2013
(2.30 pm) (Pages 7 - 10)
(c)
Planning, Protective Services and Licensing Committee 20 February 2013
(2.50 pm) (Pages 11 - 12)
(d)
Planning, Protective Services and Licensing Committee 20 February 2013
(3.10 pm) (Pages 13 - 14)
(e)
Planning, Protective Services and Licensing Committee 20 February 2013
(3.30 pm) (Pages 15 - 18)
(f)
Planning, Protective Services and Licensing Committee 25 February 2013
(10.30 am) (Pages 19 - 22)
E1
(g)
Planning, Protective Services and Licensing Committee 25 February 2013
(10.50 am) (Pages 23 - 26)
(h)
Planning, Protective Services and Licensing Committee 25 February 2013
(11.10 am) (Pages 27 - 28)
(i)
Planning, Protective Services and Licensing Committee 25 February 2013
(11.30 am) (Pages 29 - 30)
(j)
Planning, Protective Services and Licensing Committee 25 February 2013
(11.50 am) (Pages 31 - 34)
4.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: TAXI FARE SCALE REVIEW
Report by Head of Governance and Law (Pages 35 - 36)
5.
ANIMAL HEALTH AND WELFARE SERVICE PLAN 2013/14
Report by Executive Director – Development and Infrastructure Services (Pages 37
- 64)
6.
LAKELAND MARINE FARMS LTD: RELOCATION OF ARDMADDY FISH FARM
COMPRISING 12 NO. 100M CIRCUMFERENCE CAGES PLUS INSTALLATION
OF FEED BARGE: PORT NA MORACHD, SEIL SOUND (REF: 11/01066/MFF)
Report by Head of Planning and Regulatory Services (Pages 65 - 176)
7.
WEST HIGHLAND HOUSING ASSOCIATION AND ARCADE BUILDING
SERVICES LTD: FORMATION OF ROUNDABOUT TO SERVE FUTURE
DEVELOPMENT LAND NORTH AND SOUTH OF THE A85, DUNBEG, OBAN:
LAND SOUTH WEST OF PENNYFUIR COTTAGE, DUNBEG (REF: 12/01520/PP)
Report by Head of Planning and Regulatory Services (Pages 177 - 204)
8.
TREE PRESERVATION ORDER
Report by Head of Planning and Regulatory Services (Pages 205 - 208)
The Committee will be asked to pass a resolution in terms of Section 50(A)(4) of the Local
Government (Scotland) Act 1973 to exclude the public for items of business with an “E” on
the grounds that it is likely to involve the disclosure of exempt information as defined in the
appropriate paragraph of Part 1 of Schedule 7a to the Local Government (Scotland) Act
1973.
The appropriate paragraph is:E1
Paragraph 13 Information which, if disclosed to the public,
would reveal that the authority proposes(a)
(b)
to give under any enactment a notice under or by virtue of which
requirements are imposed on a person; or
to make an order or direction under any enactment.
PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
Councillor Gordon Blair
Councillor Robin Currie
Councillor George Freeman
Councillor David Kinniburgh
Councillor Robert Graham MacIntyre
Councillor Alex McNaughton
Councillor Sandy Taylor
Contact: Fiona McCallum
Councillor Rory Colville
Councillor Mary-Jean Devon
Councillor Fred Hall
Councillor Alistair MacDougall
Councillor Donald MacMillan
Councillor James McQueen
Councillor Richard Trail
Tel. No. 01546 604392
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Page 1
Agenda Item 3a
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on WEDNESDAY, 20 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Robin Currie
Councillor David Kinniburgh
Councillor Alistair MacDougall
Councillor Robert G MacIntyre
Attending:
1.
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor James McQueen
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Angus Gilmour, Head of Planning and Regulatory Services
Richard Kerr, Principal Planning Officer
Sheila MacFadyen, Senior Solicitor
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Gordon Blair, Rory
Colville, Mary-Jean Devon, George Freeman and Fred Hall.
2.
DECLARATIONS OF INTEREST
Councillor Donald MacMillan declared a non financial interest in relation to
planning application reference 12/00886/PP as the Applicant had made prior
contact with him regarding this application.
Councillor Sandy Taylor also declared a non financial interest in relation to
planning application reference 12/00886/PP as he had received representations
from and met with the Applicant in respect of this Application.
Councillors MacMillan and Taylor left the room and took no part in the discussion
of this Application which is dealt with at item 5 of this Minute.
3.
MINUTES
(a) The Minutes of the Planning, Protective Services and Licensing Committee
of 23 January 2013 at 10.30 am were approved as a correct record.
(b) The Minutes of the Planning, Protective Services and Licensing Committee
of 23 January 2013 at 2.00 pm were approved as a correct record.
(c) The Minutes of the Planning, Protective Services and Licensing Committee
of 28 January 2013 were approved as a correct record.
(d) The Minutes of the Planning, Protective Services and Licensing Committee
of 30 January 2013 were approved as a correct record.
Page 2
4.
TAXI AND PRIVATE CAR HIRE LICENSING - PROPOSALS FOR CHANGE A PUBLIC CONSULTATION BY THE SCOTTISH GOVERNMENT
The Scottish Government has issued a consultation document proposing a
range of changes to the current regime which aims to tighten up the licensing
process for taxi and private hire drivers, vehicles and booking offices. The
Scottish Government advise any changes made should support the local
authorities and the police in creating and managing appropriate local
arrangements and that they want to bring all drivers and firms up to the correct
standards to benefit people and business who make use of and rely on these
services. A report presenting a draft response to this consultation was before
the Committee for consideration.
Decision
Approved the terms of the response to the consultation and agreed that it be
submitted to the Scottish Government by the closing date of 15 March 2013.
(Reference: Report by Executive Director – Customer Services dated 28 January
2013, submitted)
Having previously declared an interest in the following item Councillors Donald
MacMillan and Sandy Taylor left the room and took no part in the discussion of this
Application.
Councillor David Kinnburgh took the Chair in Councillor Sandy Taylor’s absence.
5.
PENTLAND DEVELOPMENT: ERECTION OF DWELLINGHOUSE: LAND TO
SOUTH OF AN STRUAN (PLOT 8S), CRAOBH HAVEN, LOCHGILPHEAD
(REF: 12/00886/PP)
The Principal Planning Officer spoke to the terms of the report advising that this
proposal seeks planning permission for the erection of one dwelling house. The
application site is located within the ‘settlement area’ of Craobh Haven as
defined by the Argyll and Bute Local Plan 2009. The site is also located within a
larger Open Space Protection Area and is contrary to the provisions of Local
Plan Policy LP REC 2. The site also lies within a Tree Preservation Order and
an Ancient Semi-Natural Woodland which have in previous decisions of the
Council been noted to be a key environmental feature of the Knapdale/Melfort
Area of Panoramic Quality and of biodiversity value. Twenty seven third party
representations have been received, four raising objection to the proposal,
twenty two offering support and one from an interested party – the Agent for the
application. In addition Councillor Philand has also indicated support. Despite
the level of representation received, the determining issue in this case is one of
the primacy of local plan policy, and prematurity in the consideration of any
potential deviation from that in the light of the impending consideration of the
future of the wider area as part of the Local Development Plan process. The
policy provision is one of record and there would be no added value by
convening a local hearing. For the reasons stated in the report it is
recommended that this application be refused.
Decision
Page 3
Agreed to refuse planning permission for the following reasons:1. The proposal would result in the loss of some 0.14ha of designated Open
Space Protection Area (OSPA) to built development. In this instance the
OSPA is neither readily accessible nor useable for recreational purposes by
the public but is a significant passive amenity resource which is valued as an
undeveloped green, woodland space which contributes significantly to
landscape character, setting of the built environment and biodiversity, and as
such is a resource which cannot readily be replaced or relocated. The
proposal is therefore contrary to the provisions of policy LP REC 2 of the
adopted ‘Argyll and Bute Local Plan’ 2009 which set out a presumption
against the development of Open Space Protection Areas as designated in
the Local Plan proposals maps.
2. The development of the application site is considered likely to give rise to
adverse effects upon the long-term viability of the existing woodland within
which it is located as a consequence of the exposure of the existing
woodland edge to construction activities and the anticipated pressure for
further tree felling to provide for the residential amenity and safety of the
proposed dwelling, which, notwithstanding the loss of recently wooded land
to built development, would compromise the available seed bank and land
suitable for natural regeneration of an ancient semi-natural woodland. Any
further tree loss arising from the development of this location would not only
erode a key landscape feature which makes a significant contribution to the
Knapdale / Melfort Area of Panoramic Quality, but would also have an
adverse impact upon the integrity of of TPO 2/11 and biodiversity value of
the wider area of Ancient Semi-Natural Woodland. The proposal is contrary
to the provisions of policies STRAT DC 7 and STRAT DC 8 of the ‘Argyll and
Bute Structure Plan’ 2002 and LP ENV 2, LP ENV 6, LP ENV 7 and LP ENV
10 of the adopted ‘Argyll and Bute Local Plan’ 2009.
3. The proposed ‘Argyll and Bute Local Development Plan’ published for public
consultation on 4th February 2013 includes for the retention of an Open
Space Protection Area which encompasses the development site and a
proposed policy which presumes against development of this land; in this
respect any determination at the current time which undermined these
proposals would be prejudicial to the Local Development Plan process.
(Reference: Report by Head of Planning and Regulatory Services dated 7
February 2013, submitted)
Councillors MacMillan and Taylor returned to the meeting and Councillor Taylor
resumed the Chair.
6.
MELFORT CARE LIMITED: SITE FOR THE ERECTION OF 24 FLATS:
OSSIANS RETIREMENT HOME, NORTH CONNEL, OBAN (REF:
12/01854/PPP)
The Head of Planning and Regulatory Services spoke to the terms of the report
advising that this application seeks planning permission in principle for the
erection of 24 flats on the site of the former Ossians Retirement Home in North
Connel. With reference to the Argyll and Bute Local Plan 2009, the application
site is situated within the ‘Settlement Zone’ for North Connel which is categorised
Page 4
as a Small Town/Village in the Local Plan. The proposal constitutes an
acceptable form of ‘medium scale’ redevelopment within the ‘Settlement Zone’
for North Connel within which there is a general presumption in favour of
residential development. There are eleven objections, as well as concerns from
the Community Council. There have been no objections or concerns raised by
statutory consultees that cannot be adequately controlled through the imposition
of planning conditions. The proposal satisfies Policies STRAT SI 1, STRAT DC
1, STRAT DC 7, STRAT DC 8, LP ENV 1, LP ENV 2, LP ENV 6, LP ENV 7, LP
ENV 19, LP HOU 1, LP HOU 2, LP HOU 4, LP SERV 2, LP TRAN 1 and LP
TRAN 6. The application is recommended for approval subject to a discretionary
hearing being held in view of the number of objections received in the context of
a small community and subject to the conditions and reasons detailed in the
report.
Decision
Agreed to hold a discretionary planning hearing on Monday 25 March 2013.
(Reference: Report by Head of Planning and Regulatory Services dated 5
February 2013, submitted)
7.
ARGYLL AND BUTE COUNCIL: CHANGE OF USE OF LAND FOR SITING OF
2 STORAGE CONTAINERS FOR TEMPORARY 2 YEAR PERIOD: WILLOW
VIEW COMMUNITY CARE CENTRE, OBAN (REF: 12/02764/PP)
The Head of Planning and Regulatory Services spoke to the terms of the report
advising that planning permission is sought to site two storage containers for a
temporary period of two years within the grounds of Willowview Community Care
Centre in Oban. Whilst this form of structure would not be considered
acceptable as a long term storage solution for the site, given the temporary
nature of the proposal and the visual appearance of the containers, it is
considered acceptable to grant permission on a temporary basis for a period of
two years to allow a more permanent solution to be considered, provided that
suitable screen fencing is secured by planning conditions.
Decision
Agreed to grant planning permission subject to the following conditions and
reasons:1. This planning permission for the use of the land as a temporary site for the
two storage containers is temporary and shall expire on 28 February 2015,
by which time the storage containers shall cease being used for storage at
the site. The storage containers shall be completely removed from the site
and the land shall be reinstated to its former condition to the satisfaction of
the Planning Authority. by 31 March 2015.
Reason: Planning permission would not normally be granted for a
development of this nature in this location on a permanent basis, as
temporary structures with limited life expectancy deteriorate over time with
adverse consequences in terms of visual impact in the local area.
2. No development shall commence on site, or is hereby authorised, until full
Page 5
details of a method of screening for the storage containers, has been
submitted to and approved in writing by the Planning Authority. Such details
shall show a close boarded timber fence to the height of the storage
containers painted a dark recessive colour, or similar solid screening
mechanism as may be approved. Such details as are approved shall be fully
implemented on site prior to the first use of the containers for storage
purposes at the site and shall be retained throughout the duration of this
temporary planning permission.
Reason: In the interests of visual amenity.
3. The development shall be implemented in accordance with the details
specified on the application form dated 05/12/12 and the approved drawing
reference numbers:
Plan 1 of 3 (Drawing Number AL(00)001)
Plan 2 of 3 (Drawing Number AL(00)002)
Plan 3 of 3 (Drawing Number AL(00)003)
unless the prior written approval of the planning authority is obtained for
other materials/finishes/for an amendment to the approved details under
Section 64 of the Town and Country Planning (Scotland) Act 1997 (as
amended).
Reason: For the purpose of clarity, to ensure that the development is
implemented in accordance with the approved details.
(Reference: Report by Head of Planning and Regulatory Services dated 30
January 2013, submitted)
The Committee resolved in terms of Section 50A(4) of the Local Government
(Scotland) Act 1973, to exclude the public for the following item of business on the
grounds that it was likely to involve the disclosure of exempt information as defined in
Paragraph 13 of Part 1 of Schedule 7A to the Local Government (Scotland) Act 1973.
8.
ASSESSMENT OF REQUEST FOR PROVISIONAL TREE PRESERVATION
ORDER
A report drawing to the Committee’s attention a request to protect specific trees
adjoining an on-going development site by means of a Tree Preservation Order
was considered.
Decision
Noted and agreed the terms of the report.
(Reference: Report by Head of Planning and Regulatory Services, submitted)
Page 6
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Page 7
Agenda Item 3b
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on WEDNESDAY, 20 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor David Kinniburgh
Councillor Alistair MacDougall
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Attending:
1.
Councillor Alex McNaughton
Councillor James McQueen
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Jane MacLeod, Applicant’s Representative
Inspector Watson, Strathclyde Police
Ms Heather Murray, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Gordon Blair, Rory
Colville, Robin Currie, Mary-Jean Devon, George Freeman and Fred Hall.
2.
DECLARATIONS OF INTEREST
None declared.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI OPERATOR'S LICENCE (D LAIRD, KINGARTH, ISLE OF BUTE)
The Chair welcomed everyone to the meeting and introductions were made.
Thereafter he outlined the procedure that would be followed and invited the
Applicant’s representative to speak in support of the Application.
Applicant
Mrs MacLeod apologised for Mr Laird’s absence at this hearing and explained
the reason for this. She advised that Mr Laird was born in Dunoon in 1963 and
moved to Bonnybridge during his school years. She advised that he moved to
Rothesay in 1984 where he worked as mechanic in a garage owned by an ex
Provost of Argyll and Bute District Council. She advised that he worked as a
mechanic during the week and in the evenings and at weekends worked as a
taxi driver for the garage. She advised that Mr Laird settled down and married in
Rothesay and had three children who have since left school. She advised that
Mr Laird moved to Inverness when his marriage broke down and that he
returned to Rothesay in 2008 and was able to get his job back with the garage.
She advised that he returned to this job just before Christmas and on a work
night out he foolishly had a drink and then drove his car resulting in him being
banned from driving for 18 months and losing his job with the garage. She
advised that Mr Laird received two endorsements on his licence and not three as
stated by the Police. Mrs MacLeod advised that Mr Laird had no previous
convictions and has had none since this incident over 4 years ago and that he
Page 8
was a law abiding citizen. She advised that he has been self employed since
then doing car repairs and cutting grass and had the lease for the putting green.
She advised that Mr Laird was anxious to return to taxi driving and that he was
well known and well respected in Rothesay and referred to 30 letters of support
for this taxi application. She advised that she was aware of a taxi petition
against this operator’s licence which has come from other taxi operators on Bute
which was understandable as no one wants competition. She advised that all of
the letters of support were from all over Bute which suggested there were not
enough operators or drivers at the moment on the island. She advised that in
terms of provision across Argyll and Bute the Oban area was best served with
177 people per taxi and that Mid Argyll was at the bottom with 500 people per
taxi. She advised that Bute was somewhere in the middle with 344 people per
taxi which suggested there was neither an under or over provision of taxis on
Bute. She advised that the provision of a taxi service on an island like Bute, Mull
or Tiree was even more important as quite often visitors to the islands arrive on
foot and make use of local taxi services and that it was essential that services
were available to promote the economic and tourist activity in an area. She
advised that Mount Stuart on Bute was one of the best tourist attractions in
Scotland. She advised that it was important to have a good and efficient
transport service which included a good and efficient taxi service. She advised
that Mr Laird had hopefully proved he is suitable to hold an operator’s licence
and taxi driver’s licence and that he is very sorry for this one incident which he
deeply regrets. She advised that for 4 years he has been conviction free and
now wished to move on with his life and start up a new business at a time when
this was a difficult thing to do. She commended the Committee to grant Mr Laird
his Taxi Operator’s Licence.
As Inspector Watson had no questions the Chair invited him to speak in support
of the Police objection.
Police
Inspector Watson advised that he and Ms Murray were representing the Area
Inspector for Rothesay and that they were not recommending that this
application be endorsed for a number of reasons. He advised that as a public
service the Police demand a high standard of integrity from a taxi driver and that
there were two issues that required to be addressed. The first was in relation to
endorsements. He advised that the Applicant had only listed two endorsements
on his application form and that he was in fact charged with three separate
offences, one for drink driving, one for careless driving and one for failing to stop
and report a road accident. The second issue was that the Applicant had still to
apply for insurance which the Applicant will find will be high as a result of the
drink driving offence. Inspector Watson advised that for the reasons stated
above the Police were not recommending that the Applicant be granted a Taxi
Operator’s Licence.
As Mrs MacLeod had no questions the Chair invited questions from Members.
Members’ Questions
Councillor Kinniburgh referred to three judgements being handed out at the
Sheriff Court but the Applicant’s Agent advising there were only two and sought
clarification on this.
Page 9
Mrs MacLeod advised that she did not think it was Mr Laird’s intention to deceive
and that this was down to a lay person filling out the application form.
Inspector Watson confirmed that there were three endorsements and that he
was not sure why only two were on the Applicant’s driving licence.
Councillor McNaughton sought clarification on where Mr Laird would be
operating his business and Mrs MacLeod advised that it was his intention to
operate throughout Bute.
The Chair reminded Members of the need to consider the issue of over provision
and that there had been no evidence presented to show that there was unmet
demand.
The Chair invited Inspector Watson and Mrs MacLeod to sum up.
Summing Up
Police
Inspector Watson advised that the Police were not recommending that this
application be granted.
Applicant
Mrs MacLeod advised that Mr Laird deeply regretted what had happened and
that he has made sure he has not been in trouble since or before then. She
advised that he was a hard working man who wanted to provide a service on
Bute and that he sees a gap in the market. She advised that he has learnt his
lesson and asked Members to give him a chance to set up his business and
serve the local community.
The Chair asked Mrs MacLeod and Inspector Watson to confirm they had
received a fair hearing and they both confirmed this to be the case.
Discussion
Councillor Trail advised that this was quite a difficult hearing. He stated that Mrs
MacLeod had given a very good character reference for the Applicant who had
made a mistake. Against that there was the Police recommending that he was
not a fit and proper person to hold a Taxi Operator’s Licence and that he had to
give a fair bit of weight to that and therefore he was really reluctant to agree to
give Mr Laird a licence.
Councillor Kinniburgh advised that he was like minded to his colleague. He
advised that the Police have given a statement that Mr Laird is not a fit and
proper person to hold a Taxi Operator’s Licence and that he was of that opinion
too. He advised that he found it hard to believe that Mr Laird had forgotten to
include the third endorsement on his application form and that he felt he was
trying to hide this information from the Members.
Councillor McNaughton advised that he was prepared to accept Mrs MacLeod’s
Page 10
reasoning and that Mr Laird had accepted that he should not have driven the car.
If Mr Laird now wished to make something of his life he was minded to give him
a chance and asked if it would be possible to grant a licence for a shorter period.
The Head of Governance and Law confirmed that if the Committee wished they
could grant a licence for a shorter period that the normal period.
Councillor MacDougall advised that he supported what Councillor McNaughton
was saying.
Councillor MacMillan advised that he had sympathy for the people who wished to
give Mr Laird a chance.
Motion
That Mr Laird was a fit and proper person and to grant him a Taxi Operator’s
Licence for a period of 12 months.
Moved by Councillor Alex McNaughton, seconded by Councillor Donald
MacMillan
Amendment
That Mr Laird was not a fit and proper person to hold a Taxi Operator’s Licence
and that even if the survey about to be carried out establishes that there was an
unmet demand for taxis on Bute Mr Laird would still not be a fit and proper
person to hold a Taxi Operator’s Licence and that his application should be
refused.
Moved by Councillor David Kinniburgh, seconded by Councillor Richard Trail
The Motion was carried by 5 votes to 3 and the Committee resolved accordingly.
Decision
To grant Mr Laird a Taxi Operator’s Licence for a period of 12 months.
(Reference: Report by Head of Governance and Law, submitted)
Page 11
Agenda Item 3c
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on WEDNESDAY, 20 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor David Kinniburgh
Councillor Alistair MacDougall
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Attending:
1.
Councillor Alex McNaughton
Councillor James McQueen
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Jane MacLeod, Applicant’s Representative
Inspector Watson, Strathclyde Police
Heather Murray, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Gordon Blair, Rory
Colville, Robin Currie, Mary-Jean Devon, George Freeman and Fred Hall.
2.
DECLARATIONS OF INTEREST
None declared.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (D LAIRD, KINGARTH, ISLE OF BUTE)
The Chair welcomed everyone to the meeting and invited the Applicant’s Agent
to speak in support of this Application.
Applicant
Mrs MacLeod apologised on behalf of Mr Laird for the incident which took place
in 2008 and for the misunderstanding on the part of Mr Laird when completing
his application form which he genuinely felt he had completed correctly. She
advised that she was satisfied by the fact that Mr Laird has been found to be a fit
and proper person to hold a Taxi Operator’s Licence and advised that Mr Laird
was a fit and proper person to hold at Taxi Driver’s Licence. She advised that Mr
Laird has worked all his days, he was born in Dunoon and educated on the
mainland and that he was committed to life in Argyll and Bute. She advised that
this was a minor blemish on his character which he would like to put behind him.
As Inspector Watson had no questions the Chair invited him to speak in support
of the Police objection.
Police
Inspector Watson advised that in summary the reasons for the objection were
the same as for the Taxi Operator’s Licence and confirmed that the Police were
Page 12
not recommending that Mr Laird be granted a Taxi Driver’s Licence.
As Mrs MacLeod and the Members had no questions the Chair invited Inspector
Watson and Mrs MacLeod to sum up.
Summing Up
Police
Inspector Watson advised that he was here on behalf of the Area Inspector for
Rothesay who did not recommend that the Taxi Driver’s Licence be granted to
Mr Laird.
Applicant
Mrs MacLeod advised that if Mr Laird was good enough to be granted a Taxi
Operator’s Licence he was good enough to be granted a Taxi Driver’s Licence.
The Chair asked Mrs MacLeod and Inspector Watson to confirm they had
received a fair hearing and they both confirmed this to be the case.
Debate
Councillor Kinniburgh advised that given his views on the granting of the Taxi
Operator’s Licence, his views on the granting of a Taxi Driver’s Licence were the
same and that Mr Laird was not a fit and proper person to hold a Taxi Driver’s
Licence. He advised that this was not a minor incident and was not minor for a
taxi driver.
Motion
That Mr Laird was not a fit and proper person to hold a Taxi Driver’s Licence and
that his application should be refused.
Moved by Councillor David Kinniburgh, seconded by Councillor Richard Trail.
Amendment
That Mr Laird was a fit and proper person and to grant him a Taxi Driver’s
Licence for a period of 12 months.
Moved by Councillor Alex McNaughton, seconded by Councillor Donald
MacMillan.
The Amendment was carried by 5 votes to 3 and the Committee resolved
accordingly.
Decision
To grant Mr Laird a Taxi Driver’s Licence for a period of 12 months.
(Reference: Report by Head of Governance and Law, submitted)
Page 13
Agenda Item 3d
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on WEDNESDAY, 20 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor David Kinniburgh
Councillor Alistair MacDougall
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Attending:
1.
Councillor Alex McNaughton
Councillor James McQueen
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Patricia O’Neill, Central Governance Manager
Inspector Watson, Strathclyde Police
Heather Murray, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were received from Councillors Gordon Blair, Rory
Colville, Robin Currie, Mary Jean Devon, George Freeman and Fred Hall.
2.
DECLARATIONS OF INTEREST
There were no declarations of interest intimated.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (G MCGUINNESS, HUNTER'S QUAY,
DUNOON)
The Chair welcomed everyone to the meeting and introductions were made.
Thereafter he outlined the procedure that would be followed. It was noted that
the applicant was not present and the Chair invited Inspector Watson to speak to
the objection to the application by Strathclyde Police.
Inspector Watson advised that Strathclyde Police were objecting to the
application on the grounds that Mr McGuinness was not a fit and proper person
to hold a taxi driver’s licence. Inspector Watson advised that after investigation it
had become apparent that the applicant actually held two driving licences and
the points that had been disclosed on the application were those that were held
on one of the licences. He told the Committee that the applicants second licence
held 5 offences and that in his opinion this had been a deliberate attempt by the
applicant to deceive the Council. Inspector Watson advised that further
investigation was being carried out and that the applicant would be prosecuted
for further road traffic offences for holding the two driving licences. He
concluded by highlighting that Strathclyde Police assert that Mr McGuinness was
not a fit and proper person to hold a taxi driver’s licence.
Members did not ask any questions.
Page 14
Inspector Watson was asked to confirm that he had received a fair hearing to
which he confirmed that he had.
Councillor Kinniburgh congratulated the Police on finding out about the two
driving licences and advised that this was a clear cut case, that Mr McGuinness
was not a fit and proper person to hold a taxi driver’s licence.
Decision
The Committee unanimously agreed to refuse the application for a taxi driver’s
licence on the basis that he was not a fit and proper person to hold a licence
given the information received from Strathclyde Police.
(Reference: Report by Head of Governance and Law dated February 2013,
submitted)
Page 15
Agenda Item 3e
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on WEDNESDAY, 20 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor David Kinniburgh
Councillor Alistair MacDougall
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Attending:
1.
Councillor Alex McNaughton
Councillor James McQueen
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Patricia O’Neill, Central Governance Manager
Inspector Watson, Strathclyde Police
Heather Murray, Strathclyde Police
Michael Gray, Applicant
APOLOGIES FOR ABSENCE
Apologies for absence were received from Councillors Gordon Blair, Rory
Colville, Robin Currie, Mary Jean Devon, George Freeman and Fred Hall.
2.
DECLARATIONS OF INTEREST
There were no declarations of interested intimated.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (M GRAY, ROSNEATH)
The Chair welcomed everyone to the meeting. Thereafter he outlined the
procedure that would be followed and invited the applicant to speak in support of
his application.
Mr Gray advised that he had previously held a taxi driver’s licence for 3 years
which had run out. He advised that he was a joiner to trade and that the building
trade had been poor recently. He advised that holding a taxi driver’s badge
would assist him financially.
Inspector Watson asked Mr Gray why if he had held a licence before was it not
disclosed on his application form and Mr Gray advised that he had missed the
renewal date by two days and this had required him to submit a fresh
application. Inspector Watson asked him to confirm if the fact that this had not
been shown on the application form was an oversight to which Mr Gray replied
that it was.
The Chair invited Inspector Watson to speak to the representation submitted by
Strathclyde Police.
Inspector Watson advised that Mr Gray had held his driving licence for 11 years
Page 16
and in that time had received 14 penalty points, 3 of which were now spent. He
advised that this showed a disregard to road traffic legislation. Inspector Watson
advised that the applicant had declared 3 offences on his application totalling 7
points and the Police letter a further case in which Mr Gray had pled guilty at
Dunoon Sheriff Court for driving at 83mph in a 60mph limit for which he had
received an £180 fine and 4 penalty points. This resulted in a current total of 11
penalty points on his licence.
Mr Gray did not have any questions for Inspector Watson.
Councillor McNaughton asked for clarification on what the offences were that Mr
Gray had declared on his application and Inspector Watson advised that the first
offence had been for speeding for which he had received 3 penalty points, the
second for failing to obey a stop sign for which he had received 3 penalty points
and the third for speeding for which he had received 4 points.
Councillor Trail asked Mr Gray if any of the offences had been committed while
he had been driving a taxi to which he replied yes, on one occasion.
Councillor Kinniburgh asked Mr Gray when his original taxi driver’s licence had
been applied for to which he replied that it had expired on 21 October 2012 so it
must have been October 2009. Councillor Kinniburgh commented that the
September 2009 offence could have been taken into account when Mr Gray
originally applied for a licence but the majority had happened after that.
Councillor MacMillan asked Mr Gray why he had failed to pay the fixed penalty
ticket for the first offence. Mr Gray advised that his lawyer had advised him to
pay his two fines at once, which he had done, he had then received a letter back
informing him that he could not pay the two together and by this point he was out
of time and his lawyer had then advised him not to pay and to let it go to a court
date.
The Chair then invited both parties to sum up.
Inspector Watson advised that the Police representation was due to the number
of offences in a short period of time, in the Glasgow area. He advised that
policing in Glasgow was much higher profile than in the Argyll and Bute area and
he was concerned that any further offences may go undetected in the area,
possibly resulting in an accident.
Mr Gray advised that all the offences had been over the past 4 years and having
the taxi badge had meant that he had been driving a lot more and it had taken
him to other places. He advised that the failure to obey a stop sign offence had
been for driving through a red light and that he had wanted to appeal against it,
his lawyer had advised him not to. He advised that Councillor Robert G
MacIntyre knew of him.
The Chair confirmed from both parties that they had been given a fair hearing.
Discussion
Councillor Robert G MacIntyre advised that Mr Gray was not a bad boy, he did
not have a criminal background and that he did a lot for the community. He
Page 17
advised that the application was to allow Mr Gray to cover for a man who was ill
and to help a family taxi business. He added that his perception was that Mr
Gray was an asset to the village and to the family taxi business.
Councillor Trail advised that although he had some sympathy for what Councillor
MacIntyre had said he was disturbed that a professional driver had such a
casual attitude to road traffic legislation.
Councillor Kinniburgh advised that he agreed with Councillor Trail and added
that he was concerned over the frequency of the offences. He added that he
was also concerned at the fact that the speeding offences had been massively
over the speed limit, 83mph in a 60mph limit and 50mph in a 30mph limit. He
advised that he had no doubts that Mr Gray was not criminal but was concerned
at the fact most of the offences had taken place in Glasgow where police
presence was prominent. Councillor Kinniburgh that he was swayed towards
possibly granting the licence due to the fact that Mr Gray now had 11 points on
his licence and 1 more offence would result in him losing his driving licence
completely but he was not 100% sure that Mr Gray had learned his lesson and
was not convinced that he wouldn’t offend again.
Councillor MacDougall asked about the possibility of reducing the time the
licence was granted for to allow Members to review it. Mr Reppke advised that
this would be possible but the fact Mr Gray had 11 points on his licence reduced
the need for this as it may encourage him not to reoffend. He advised that it
would be at the Committees discretion.
Councillor Kinniburgh asked how many years it would be until the points came
off Mr Gray’s licence. Mr Reppke advised that points stayed on a licence for 3
years and Inspector Watson advised that the first of the points would come off
the licence in January 2014.
Councillor Robert G MacIntyre advised that it would be another year until the
points would come off the licence and the fact that he may lose his licence if he
committed one more offence would always be at the back of Mr Gray’s mind.
The Chair advised that he supported Councillor Trail and added that he would
not like to see people applying for licences through the Committee with 9, 10 or
11 points on their licence all the time. People applying for licences would be
responsible for the safety of others who they carry in their taxis and should be
able to demonstrate that they are safe drivers, who know and comply with the
law.
Motion
To grant the application for a taxi driver’s licence for a period of 3 years.
Moved Councillor R G MacIntyre, seconded Councillor MacDougall
Amendment
To refuse the application for a taxi driver’s licence on the basis of the concerns
raised by Strathclyde Police.
Page 18
Moved Councillor Trail, seconded Councillor Taylor.
Decision
Following a show of hands vote the Motion was carried by 5 votes to 3 and the
Committee resolved accordingly.
(Reference: Report by Head of Governance and Law dated February 2013,
submitted)
Page 19
Agenda Item 3f
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on MONDAY, 25 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Gordon Blair
Councillor Rory Colville
Councillor Robin Currie
Councillor Fred Hall
Attending:
1.
Councillor Alistair MacDougall
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Kate Connelly, Trainee Solicitor
Irene Willis, Applicant
Frank Collins, Applicant’s Agent
Kim Naismith, Agent’s Assistant
Inspector Harper, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Mary-Jean Devon,
George Freeman, David Kinniburgh and James McQueen.
2.
DECLARATIONS OF INTEREST
None declared.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR
AMENDMENT OF SKIN PIERCING AND TATTOOING LICENCE (I WILLIS,
HELENSBURGH)
The Chair welcomed everyone to the meeting and introductions were made.
The Head of Governance and Law advised Members that an objection from
Strathclyde Police had been received out with the time period allowed by the
Civic Government (Scotland) Act 1982 for making objections or representations.
He advised that the Police had submitted an objection on time but this had been
withdrawn and replaced with an updated version which arrived late and it was for
the Members to decide whether or not to take into consideration this late
representation.
The Applicant’s Agent advised that he understood this was a representation from
the Police and not an objection and that he and his client had no objection to this
representation being taken into consideration by the Members.
The Members agreed to consider this late submission from the Police and copies
were circulated.
The Chair went on to outline the procedure that would be followed during the
Hearing and invited the Applicant’s Agent to speak in support of the Application.
Page 20
Applicant
Mr Collins advised that this was an amendment to a licence granted to Miss
Willis in December 2012. He advised that Miss Willis had intended from the start
to employ Mr Walls who was an experienced tattooist who was well known in his
field and had a considerable number of clients. He advised that Miss Willis has
three young children and needs assistant to help run her business. He advised
that Mr Walls has been employed by a number of tattooists in Glasgow where it
was not a requirement for employees to be on the employer’s licence. Mr Collins
advised that Miss Willis had received a visit from an Environmental Health
Officer prior to opening her business and had mentioned that she intended to
employ Mr Walls. The Environmental Health Officer had stated to Miss Willis
that she may wish to check whether or not her tattoo licence would need
amended if she intended employing another tattooist and that conversation had
resulted in her application for the amendment to her tattoo licence. Mr Collins
confirmed that Mr Walls had convictions and that these were accepted.
However, he advised that he did not think these were relevant to working in a
tattoo parlour. He referred to the regulations for operating a tattoo parlour
relating to cleanliness and the hygiene of the premises and that Mr Walls’
previous convictions should not prevent him from working in a tattoo parlour. He
advised that Mr Walls has been a tattooist for many years. He advised that
lately he had been working as a welder but due to a shoulder injury this was no
longer possible so was returning to work as a tattooist. Mr Collins advised that
Miss Willis had a list of clients for February who had all paid a deposit which had
to be returned when they realised that Mr Walls would not be there as this
application had still to be considered. He advised that if this application is not
granted Miss Willis thinks it will be extremely unlikely she will be able to make a
go of her business. He advised that Mr Walls will be an employee of a business
controlled by Miss Willis and that his convictions were not relevant to the work of
a tattooist and asked the Committee to grant the amendment to the licence.
As Inspector Harper had no questions the Chair invited him to speak in support
of the Police representation.
Police
Inspector Harper confirmed that the Police representation was in respect of Mr
Walls’ previous convictions and the nature of these convictions, one relating to
breach of the peace and one relating to assault which demonstrated he is
capable of violence which the Members should take into consideration.
As Mr Collins had no questions the Chair invited the Members to ask questions.
Members’ Questions
Councillor MacMillan referred to the previous convictions which the Police stated
were aggressive in nature and asked if Mr Walls had received treatment for his
aggression.
Mr Collins advised that both incidents involved alcohol and that Mr Walls had
turned himself in for the second offence. He advised that Mr Walls was an
experienced tattooist and that he did not have a drink problem and he did not
Page 21
think it was being suggested that Mr Walls was a danger to the public.
Councillor MacMillan sought confirmation on whether or not Mr Walls had
received treatment for his aggression and Mr Collins advised he did not know.
Councillor Trail advised that he has never had experience of a tattoo parlour but
imagined that it was basically a one to one appointment with the tattooist and the
customer. He advised he was concerned if people knew of Mr Walls’ previous
convictions would they be happy to be in a one to one situation with him.
Miss Willis advised that Mr Walls has a very large client base and to be a
tattooist you had to have a good trusting relationship with your clients. She
advised that Mr Walls has a very good reputation and has no problem in carrying
out his work or with any clients he has worked with.
Councillor Blair referred to the Health and Safety aspect of working in a tattoo
parlour and Miss Willis having an obligation to look after her customers and
asked if Mr Walls would be in her employ and Miss Willis replied yes.
Councillor Blair referred to the details of the assault carried out by Mr Walls and
referred to the need when working in this type of environment with blood there
would be a need to be careful of contamination of blood and asked if Miss Willis
was happy to have a prospective employee who could behave in the way he did
during the assault.
Miss Willis advised that she was not aware of Mr Walls’ history and that she was
concerned with the level of his work, cleanliness etc and not with his past.
Mr Collins advised that the incident happened nearly 5 years ago and if this
application had come a few months later this conviction would be spent.
Councillor Blair advised that if he ran a business and was aware of the details of
this conviction on a CV it would ring alarm bells.
Mr Collins advised that Miss Willis has known Mr Walls for a long time and that
he trained Miss Willis in the art of tattooing.
Councillor Currie asked Mr Collins if he would agree there was no history of
trouble. These two separate incidents had happened 5 and more years ago and
that people do change. He advised that none of these incidents had happened
at work and asked Mr Collins if he agreed that people can be good at their work
but different away from work.
Mr Collins advised that he did agree with these statements and confirmed that
work wise Mr Walls has had no issues.
Councillor Colville asked Inspector Harper to confirm if Mr Walls had not reported
the assault himself the Police would not have been aware of it.
Inspector Harper confirmed that this was possible.
Councillor Colville referred to the incident being over 5 years ago and asked
would this type of incident not have been seen again if there was a pattern.
Page 22
Inspector Harper advised that domestic violence was very under reported but
you could expect calls from neighbours reporting disturbances and that there has
been no evidence of that in this case.
The Chair invited Inspector Harper and Mr Collins to sum up.
Summing Up
Police
Inspector Harper advised that this was purely a representation on behalf of the
Chief Constable involving Mr Walls’ previous history.
Applicant
Mr Collins advised that Miss Willis has three young children and that she was
previously on benefits. She received a small legacy following the death of her
Grandfather and had used this money to set up her business. He advised that
she wants to make a go of her business but needs assistance. He advised that
Mr Walls is an experienced tattooist and that his two previous convictions were 5
and 13/14 years ago. He asked the Committee to give Mr Walls a chance and to
give Miss Willis a chance to make a go of her business.
The Chair asked both parties to confirm they had received a fair hearing and
they confirmed this to be the case.
Decision
Agreed to grant the amendment of Miss Willis’ Skin Piercing and Tattooing
Licence to name Mr William Walls as a practitioner who will give treatments at 12
Colquhoun Street, Helensburgh, G84 8AJ.
(Reference: Report by Head of Governance and Law, submitted and Letter of
representation from Strathclyde Police, tabled)
Page 23
Agenda Item 3g
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on MONDAY, 25 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Gordon Blair
Councillor Rory Colville
Councillor Robin Currie
Councillor Fred Hall
Councillor Alistair MacDougall
Attending:
1.
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Kate Connelly, Trainee Solicitor
Pawel Skibinski, Applicant
Inspector Harper, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Mary-Jean Devon,
George Freeman, David Kinniburgh and James McQueen.
2.
DECLARATIONS OF INTEREST
None declared.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR THE
GRANT OF A SECOND HAND DEALER'S LICENCE (P SKIBINSKI, OBAN)
The Chair welcomed everyone to the meeting and introductions were made.
Thereafter he outlined the procedure that would be followed and invited the
Applicant to speak in support of his Application.
Applicant
Mr Skibinski advised that he established his business 3 years ago as a second
hand dealer in Oban. He advised that his licence expired and that he was now
applying for a new one to include opening a new shop in Campbeltown. He
advised that he had noted he had made a mistake when he did not declare his
previous convictions on his Application form.
As Inspector Harper had no questions the Chair invited him to speak in support
of the Police objection.
Police
Inspector Harper advised that the Chief Constable was objecting to this
Application based on the Applicant’s previous convictions and his failure to
declare these.
As Mr Skibinski had no questions the Chair invited the Members to ask
questions.
Page 24
Members’ Questions
Councillor Hall asked which conviction Section 7 (2) of the Civic Government
(Scotland) Act 1982 related to.
Inspector Harper advised that this was in respect of failing to declare previous
convictions.
Councillor Currie asked why the Applicant had failed to declare his conviction.
Mr Skibinski advised that he thought convictions related to crimes like robberies
or theft and that he did not realise road traffic offences should be declared.
Councillor Currie sought clarification on what the 2012 conviction was.
Inspector Harper advised that the same offence had been committed when the
Applicant had applied for a taxi driver licence and failed to declare previous
convictions and this had resulted in a conviction under the Civic Government
(Scotland) Act 1982 Section 7 (2). He advised that the Applicant had now
applied for a Second Hand Dealers licence and made the same mistake and it
was not clear if this was error or intent to deceive.
Councillor Currie asked Mr Skibinski to comment.
Mr Skibinski advised that he did not understand the conviction dated 2012 as he
had not been in court about this and had not received any paperwork regarding
it.
Councillor Taylor sought clarification from Inspector Harper.
Inspector Harper advised that this was listed as a non conviction disposal from
the Sheriff’s Office in Dunoon. He advised that it was a Fiscal’s warning which is
normally advised by a Fiscal’s letter being issued.
Councillor Trail noted that Mr Skibinski had premises in Oban and asked why he
wished to open premises in Campbeltown.
Mr Skibinski advised that he wished to expand his business and that his
customer base would be bigger in Campbeltown as there were no other second
hand dealer shops in that town.
Councillor Blair asked if it was normal for the Crown Office to send out letters to
work addresses rather than home addresses and would this explain why Mr
Skibinski did not receive any letter regarding this conviction.
Inspector Harper advised that it would depend on the address listed in the Police
report which would have been supplied by the individual concerned.
Councillor MacMillan asked where in Campbeltown the shop would be based.
Mr Skibinski confirmed this would be 6 Longrow South and that it was closed at
the moment and still to be fitted.
Page 25
The Chair invited Inspector Harper and Mr Skibinski to sum up.
Summing Up
Police
Inspector Harper advised that the Chief Constable objected to this Application
due to the Applicant’s previous conviction history and for failing to declare these
convictions.
Applicant
Mr Skibinski referred to the conviction dated 29 July 2012 relating to failure to
declare convictions and advised that he did not receive a letter regarding this
and did not pay a fine. He advised that the only letter he has received from
Dunoon was one dated January 2013.
The Chair asked both parties to confirm if they had received a fair hearing and
they both confirmed this to be the case.
Discussion
Councillor Hall advised that he was still swithering and that he still needed to be
reassured that the omission of the convictions on the application form was an
omission and not a deliberate intention to mislead.
Councillor Colville advised that he was reassured as the Procurator Fiscal had
decided just to issue a warning so he was inclined to support the Application.
Councillor Currie sought and received clarification on the nature of the most
recent conviction from the Head of Governance and Law.
Councillor MacMillan advised that he had a lot of sympathy for the Applicant. He
advised that there are always complaints about shops lying empty and that he
would be happy to support this Application.
Councillor Blair advised that it was always a concern when people ticked the
wrong box. He advised it was also an issue when fines were unpaid and that
this was an opportunity to remind people to pay outstanding fines.
The Chair noted that it appeared that some Members were in support of this
Application and asked if any were otherwise minded. Councillor Hall indicated
that having listened to the debate he was not in favour of granting this
Application.
Decision
Agreed to grant a Second Hand Dealer’s Licence to Mr Pawel Skibinski to trade
at 1A Combie Street, Oban, PA34 4HN and 6 Longrow South, Campbeltown,
PA28 6AH.
(Reference: Report by Head of Governance and Law, submitted)
Page 26
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Page 27
Agenda Item 3h
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on MONDAY, 25 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Rory Colville
Councillor Robin Currie
Councillor Fred Hall
Councillor Alistair MacDougall
Attending:
1.
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Kate Connelly, Trainee Solicitor
Scott Robertson, Applicant
Inspector Harper, Strathclyde Police
APOLOGIES FOR ABSENCE
Apologies for absence were intimated from Councillors Gordon Blair, Mary-Jean
Devon, George Freeman, David Kinniburgh and James McQueen.
2.
DECLARATIONS OF INTEREST
None declared.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (S ROBERTSON, OBAN)
The Chair welcomed everyone to the meeting and introductions were made.
Thereafter he outlined the procedure that would be followed and invited the
Applicant to speak in support of his Application.
Applicant
Mr Robertson advised that he was applying for a Taxi Driver’s Licence and
confirmed that it was his fault for not declaring his previous conviction on the
Application form as he thought it had been spent and that he had not meant to
hide anything. He advised that he was previously employed as a Support
Worker working with people with learning difficulties and his conviction had not
come up in his disclosure.
As Inspector Harper had no questions the Chair invited him to speak in support
of the Police representation.
Police
Inspector Harper advised that the Chief Constable wished to make a
representation due to the Applicant’s previous conviction not being declared on
his Application form. He advised that the Applicant had been charged with
failing to declare his conviction and that he was not aware of the Fiscal decision
Page 28
on this charge.
Applicant’s Questions to Police
Mr Robertson asked Inspector Harper to note that he had received confirmation
from the Fiscal that the case would not be taken any further.
Members’ Questions
Councillor Colville noted that the Applicant’s driving licence would expire in 2014
and sought clarification on this.
Mr Robertson advised that he was a diabetic and was required to renew his
licence every 3 years.
Councillor Currie sought and received clarification on the nature of the
Applicant’s conviction.
Councillor Trail sought and received confirmation that Mr Robertson’s diabetes
was under control.
Councillor Trail referred to Mr Robertson previously having a Taxi Driver’s
Licence.
Mr Robertson confirmed that he did have a Taxi Driver’s Licence a number of
years ago but never used it.
Councillor Trail asked if he was granted a licence now would he use it and Mr
Robertson confirmed that he would as he was currently unemployed.
The Chair invited Inspector Harper and Mr Robertson to sum up.
Summing Up
Police
Inspector Harper advised that he had nothing further to add.
Applicant
Mr Robertson apologised again for not declaring his previous conviction on the
application form.
The Chair invited both parties to confirm they had received a fair hearing and
they both confirmed this to be the case.
Decision
Agreed to grant a Taxi Driver’s Licence to Mr Scott Robertson.
(Reference: Report by Head of Governance and Law, submitted)
Page 29
Agenda Item 3i
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on MONDAY, 25 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Rory Colville
Councillor Robin Currie
Councillor Fred Hall
Councillor Alistair MacDougall
Attending:
1.
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Kate Connelly, Trainee Solicitor
Inspector Harper, Strathclyde Police
Mr Tolmie, Applicant
APOLOGIES FOR ABSENCE
Apologies for absence were received from Councillors Blair, Devon, Freeman,
Kinniburgh and McQueen.
2.
DECLARATIONS OF INTEREST
There were no declarations of interest intimated.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (S TOLMIE, CAMPBELTOWN)
The Chair welcomed everyone to the meeting and introductions were made.
Thereafter the Chair outlined the procedure that would be followed and invited
the applicant to speak in support of his application.
Mr Tolmie advised that he was applying because he was currently unemployed.
He advised that in December 2008 he had been convicted of drink driving. He
advised that it had been the biggest mistake of his life and that he had never
driven a car drunk before this incident or since this incident. He added that this
one moment of madness had ruined his life.
Inspector Harper had no questions.
Inspector advised that the Chief Constable’s representation was on the grounds
of the applicant’s conviction relating to drunk driving for which he had received a
£400 fine and a 12 month driving ban.
Mr Tolmie had no questions for Inspector Harper.
Councillor Robert Graham MacIntyre asked for clarification on why the
applicant’s conviction would remain unspent. Inspector Harper advised that due
to the type of conviction and the fact that the applicant would be coming into
Page 30
contact with the public, the conviction would always remain unspent for this type
of application.
The Chair invited both parties to sum up.
Inspector Harper advised that the representation by Strathclyde Police was due
to the drink driving conviction on the applicant’s previous history.
Mr Tolmie advised that it had been one moment of madness and the licence
would be a fresh start and an opportunity to build his life up again.
The Chair asked both parties to confirm that they had received a fair hearing to
which they confirmed that they had.
Councillor Colville advised that he understood why the application was before
the Committee but that he had no problem in supporting the application.
Decision
The Committee unanimously agreed to grant the application for a taxi driver’s
licence for a period of 3 years.
(Reference: Report by Head of Governance and Law dated February 2013,
submitted)
Page 31
Agenda Item 3j
MINUTES of MEETING of PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE
held in the COUNCIL CHAMBERS, KILMORY, LOCHGILPHEAD
on MONDAY, 25 FEBRUARY 2013
Present:
Councillor Sandy Taylor (Chair)
Councillor Rory Colville
Councillor Robin Currie
Councillor Fred Hall
Councillor Alistair MacDougall
Attending:
1.
Councillor Robert G MacIntyre
Councillor Donald MacMillan
Councillor Alex McNaughton
Councillor Richard Trail
Charles Reppke, Head of Governance and Law
Graeme Forrester, Solicitor
Kate Connelly, Trainee Solicitor
Inspector Harper, Strathclyde Police
Mr Berry, Applicant
APOLOGIES FOR ABSENCE
Apologies for absence were received from Councillors Blair, Devon, Freeman,
Kinniburgh and McQueen.
2.
DECLARATIONS OF INTEREST
There were no declarations of interest intimated.
3.
CIVIC GOVERNMENT (SCOTLAND) ACT 1982: APPLICATION FOR GRANT
OF TAXI DRIVER'S LICENCE (C BERRY, CRAOBH HAVEN, BY
LOCHGILPHEAD)
The Chair welcomed everyone to the meeting and introductions were made. He
thereafter outlined the procedure that would be followed and invited the applicant
to speak in support of his application.
Mr Berry advised that he currently stayed in Croabh Haven with his father, who
was the General Manager of the Marina. He advised that there was a
requirement for a taxi service within the Croabh Haven and Craignish area and
that there was one other service currently operating in the area but it was not
regular or reliable. He added that his father had offered to fund the business as
it would benefit the Marina. Mr Berry advised that he recognised that he had
problems in the past but was now addressing them and would like to get back
into employment to give him something to focus on.
Inspector Harper had no questions for Mr Berry.
Inspector Harper advised that the Chief Constable’s objection was based on the
applicant’s previous convictions and recent history involving the Police.
Inspector Harper gave details of the convictions as listed on the letter from
Strathclyde Police and gave information on a further three incidents which had
taken place on 14 August 2011, 28 June 2012 and 21 August 2012. Inspector
Page 32
Harper advised that Strathclyde Police were concerned that the safety of the
public would be compromised as a result of these convictions and incidents.
Mr Berry had no questions for Inspector Harper.
Councillor Colville noted that there had been an objection to this application from
Strathclyde Police as opposed to a representation and asked if an objection from
the Police should be given more weight than a representation. Inspector Harper
advised that normally representations are submitted to draw the Committees
attention to previous convictions whereas an objection would be submitted
should the Police feel that public safety may be compromised. He advised that
in this case the objection was submitted due to the nature of the incidents and
due to how recent they had been.
Councillor Colville asked Mr Berry if he was attending recognised treatment and
Mr Berry advised Councillor Colville of two organisations he was currently
receiving treatment from.
The Chair invited both parties to sum up.
Inspector Harper advised that the Police objection was due to the nature of the
incidents and the fact that they had taken place recently.
Mr Berry advised that he had nothing to add.
The Chair asked both parties to confirm that they had received a fair hearing to
which they both confirmed that they had.
Discussion
Councillor Trail advised that normally he would be willing to give a second
chance but in this case he felt that the incidents had been too recent and that it
was too early for Mr Berry to have benefited from any treatment he was
receiving.
Councillor Hall advised that conveying the public from one place to another was
a very responsible job and due to the types of convictions Mr Berry held he was
of the opinion that the licence should not be granted.
Councillor McNaughton advised that he felt Mr Berry should be given a second
chance and suggested the use of conditions to control the grant of a licence to
Mr Berry.
Councillor Currie advised that he agreed with Councillor McNaughton and
suggested a probationary period or some strict conditions should be placed on
the grant of any licence.
Mr Reppke advised that the licence could be granted for a shorter period which
would result in the need for a new application to come before Members at the
point when the licence ran out. Mr Reppke advised that he was unsure of what
strict conditions could be placed on the grant of a licence and advised that any
further incidents similar to Mr Berry’s previous behaviour would be dealt with by
the Law and flagged up to Members at the stage of reapplication.
Page 33
Councillor Colville advised that he would have liked to see some clear evidence
of Mr Berry maintaining his rehabilitation programme over a longer period of time
before he granted him with a licence.
Councillor Taylor advised that he was receiving a general feeling amongst
Members that they felt some sympathy towards Mr Berry but felt that more time
was needed to ensure that Mr Berry was benefiting from his treatment before
awarding a licence to him.
Decision
The Committee unanimously agreed to refuse the application for a taxi driver’s
licence on the basis of the objection received from Strathclyde Police.
(Reference: Report by Head of Governance and Law dated February 2013,
submitted)
Page 34
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Page 35
Agenda Item 4
ARGYLL AND BUTE COUNCIL
PLANNING, PROTECTIVE
SERVICES AND LICENSING
COMMITTEE
CUSTOMER SERVICES
20th March 2013
CIVIC GOVERNMENT (SCOTLAND) ACT 1982
TAXI FARE SCALE REVIEW
1.
SUMMARY
1.1
In terms of the Civic Government (Scotland) Act 1982, Section 17, the
Local Authority requires to fix maximum fares and other charges in
connection with the hire of taxis operating in their area and to review the
scales for taxi fares and other charges on a regular basis.
1.2
A report was placed before the Committee on 23rd January 2013 inviting
them to consider the representations received in response to a
consultation carried out regarding the review of fares and to decide on
what course of action to take. The Committee thereafter agreed to
propose that there be no change to the current fare structure and charges
and to review the position in 6 months’ time if representations in respect
of this proposal are received. It also authorised the Head of Governance
and Law to advertise the proposed no change in tariff and invite any
responses within one month of the advertisement and report back to
Members at this meeting
The proposal not to amend fares for taxis operating in the area was
published in the local press week commencing 27th January 2013. The
advert stated this proposal will become effective from 30th April 2013 and
anyone wishing to make any representations by no later than 4th March
2013.
2.
RECOMMENDATIONS
2.1
The Committee are asked to:
• Note the lack of representations received following the publication of the
proposal that the charges will remain the same;
3.
DETAIL
3.1
No representations have been received from the taxi trade or members of
the public following the adverts.
Page 36
4.
CONCLUSION
4.1
Members are asked to:
a) note the position in relation to the review of fares and agree to
publicise the new fare structure which will provide a final
opportunity for the trade to appeal to the traffic commissioners ,if
so advised
and
b) note the previous decision that a report come back in six months
in the event of any representations from the trade on when to
commence the next review of fare scales.
All taxi operators require to be given notice of the scales fixed,
Members should be aware that any person or any persons or
organisations appealing to the Traffic Commissioner to be
representative of taxi operators in the area who operates a Taxi in an
area for which scales have been fixed or in respect of which a review
has been carried out will still have the opportunity to lodge an appeal to
the Scottish Traffic Commissioner within a 14 day period.
5.
IMPLICATIONS
5.1
Policy – None
5.2
Financial – None
5.3
Legal – The Council require to review taxi fares in terms of the Civic
Government (Scotland) Act 1982
5.4
HR – None
5.5
Equalities – None
5.6
Risk – None
CHARLES REPPKE
Head of Governance and Law
For further information contact: Alison MacNab
Tel: 01546 604198
Page 37
ARGYLL AND BUTE COUNCIL
DEVELOPMENT &
INFRASTRUCTURE SERVICES
Agenda Item 5
PLANNING, PROTECTIVE SERVICES
AND LICENSING COMMITTEE
20th MARCH 2013
ANIMAL HEALTH & WELFARE SERVICE PLAN 2013/2014
1.
2.
PURPOSE
1.1
The Council has a statutory responsibility to deliver an animal health
and welfare service, and this is undertaken by competent and
authorised Officers within the Council’s Regulatory Services.
1.2
The Scottish Government have implemented a Framework Document
which specifies the component parts of an animal health and welfare
service, and prescribed minimum best practice and good practice
standards upon which Local Authorities are assessed. This report
details the Animal Health & Welfare Service Plan for 2013/2014 to
meet the Framework.
RECOMMENDATIONS
2.1
3.
That Members note the work of the animal health and welfare service,
its status against the Framework standard, and formally approve the
Service Plan for 2013/2014.
BACKGROUND
3.1
Animal health and welfare responsibilities are wide-ranging and cover
inspections of farms and markets, responding to service requests, work
in respect of the investigation and control of animal and zoonotic (can
be transmitted to humans) diseases, and the disposal of animal byproducts. We also have good communications with the agricultural
sector and other agencies, including the SSPCA, Animal Health &
Veterinary Laboratory Agency (AHVLA) and the Scottish Government
Rural Payments Inspectorate (SGRPID).
3.2
An Animal Health & Welfare Framework was introduced in 2011, and
last year’s Plan had regard to this document. We had various
concerns on the Framework relating to the absence of a risk-based
approach (particularly for Markets) the inadequacies of the national
software system (AMES) and some other activities. As a result of a
subsequent meeting with the Scottish Government, the Framework has
been revised and there is an ongoing agenda to amend and develop
the Framework. At a national level, the Council’s Regulatory Services
Manager represents Scottish Local Authorities on the Framework
Steering Group and National Strategy Group.
Argyll and Bute Council Service Profile 13-14
Page 38
3.3
As a service, we have had an improvement agenda in place for some
years, and the requirements of the Framework for Service Plans,
performance measures, and risk-based inspections were already in
place. In the period 2012 – 2013 specific achievements of the service
have been :
(i)
The high-risk inspection programme for animal health and
welfare has been completed, with 100% of all works being
achieved.
(ii)
We have responded to 91.3% service requests within 20
working days, exceeding our target of 90%. This, however, has
been at the expense of medium-risk visits.
(iii)
We have introduced a novel approach to Market visits as we
believe the minimum standards requiring attendance at 75% of
sale days by enforcement personnel for 25% of operating hours
is inappropriate and would require 1.2 FTE from our 2 FTE staff
resource. Our strategy is risk-based, focusing on specific areas
(e.g., structure, management, biosecurity, transportation and is
subject to further development. It has been resource-intensive
as it has identified areas for further investigation; but has been
generally welcomed by the industry; has improved standards,
and is being considered nationally, as an alternative to how
Market inspections are undertaken in Scotland.
(iv)
We have introduced and undertaken our alternative enforcement
work which targeted at low-risk visits, providing advice and
information so that they can assist themselves in complying with
standards. This has included as newsletter to the framing
community advising on issues and developments in animal
health and welfare.
(iv)
Customer satisfaction surveys have indicated levels of 93% for
animal health and welfare.
(vi)
We have secured joint working arrangements 7 other Local
Authorities to share access and use of our mobile animal
carcass incinerator. This reduces the costs to the service,
increases our income, and demonstrates the joint
working/shared
services
approach
for
contingency
arrangements.
(vii)
At an operational level, the main challenges have been :•
Meeting targets with the increasing trend of service
enquiries which shows a 50% increase year on year
since 2009
Argyll and Bute Council Service Profile 13-14
Page 39
(vii)
3.4
•
The Market strategy has been well received by markets
operators, auctioneers and the industry; and has
identified the standards across Argyll and Bute are
generally good. As with any inspection or audit, they
have identified issues which we did not anticipate which
have required attention.
•
We were involved in a major Scottish wide investigation
concerning the illegal use of cattle passports. This
resulted in a multiagency investigation, coordinated by
Central Police, and a successful prosecution.
•
Supporting the AHVLA in response to a series of welfare
concerns on farms. These required significant resources
from the Council and whilst the four major farming
operations with inherent welfare problems have
addressed and rectified these concerns, there are two
prosecutions pending.
In terms of service improvement, we have integrated general
enquiries into the Council’s Customer Contact Centre, have
implemented an electronic document management system for
animal health and welfare which supports document control and
flexible working, and.
The Service Plan 2013/2014, in Appendix I, builds upon the success of
2012/2013, and outlines our priorities, and targets for the forthcoming
year :(i)
Achieve a target of 100% of high risk visits
(ii)
Achieve 90% of the programme of planned market
interventions.
(iii)
Resolve 85% of all service requests within 20 working
days
(iv)
Deliver our alternative enforcement plan for animal health
and welfare focussing on aspects including traceability;
transportation of livestock, biosecurity and horse
passports,
(v)
Build upon the joint working arrangements in place with
the SSPCA, AHVLA, local authorities and other agencies
Argyll and Bute Council Service Profile 13-14
Page 40
(vi)
3.5
Review our risk assessment scheme and the risk rating
all premises.
The Animal Health and Welfare Framework has 28 assessment criteria
and specifies the standards for each ranging from the minimum
standard to in many cases, best practice and good practice standards.
There are some measures which only have minimum standards. This
enables local authorities to design and assess their services against
each of the standards.
In Argyll and Bute, we come out favourably and there are a number
where a novel or unique approach has been agreed with AHVLA as the
minimum standards is inappropriate (e.g. the quantitative visit regime
for markets etc.). Appendix II shows the Council position for each
activity against the national standards. In summary, I would gauge our
service as being good practice with examples of better practice
3.6
This Service Plan has been discussed and agreed with AHVLA, as
required in the Framework. We have built in activities they will
undertake, to reflect the partnership arrangement (see Section 9.2).
In a recent Paper produced by AHVLA to the Animal Health and
Welfare Strategy Group, they indicate that 18 of 31 Local Authorities
are signed up to the Framework and Argyll and Bute Council is
“proactive, risk-based, and are at the forefront of animal health
and welfare regulation in Scotland.”
4.
CONCLUSIONS
4.1
5.
The Animal Health & Welfare Service Plan 2013/2014 meets our
statutory responsibilities, targets resources at key priorities, and meets
the national Framework Document.
IMPLICATIONS
Policy :
None
Financial :
The Service Plan will be delivered on the existing
budget
Personnel :
None
Equal Opportunity :
We have a risk-based, proportionate approach to
enforcement for all activities
Argyll and Bute Council Service Profile 13-14
Page 41
Risk
The Service Plan meets the Framework Document
and our focus will be on delivering the operational
service plan. Notwithstanding this, performance will
be adversely affected where we are required to
respond to any event (e.g., Foot & Mouth; livestock
seizure etc.) or where there are staff absence
Legal
Meets the Council’s statutory duties for animal
health and welfare
ALAN MORRISON
REGULATORY SERVICES MANAGER
AM/KT/ 7057 Feb 2013
For further information
contact:
Tel: 01546 604292
Alan Morrison
Regulatory Services Manager
e-mail : [email protected]
Argyll and Bute Council Service Profile 13-14
Page 42
Argyll and Bute Council Service Profile 13-14
ARGYLL AND BUTE COUNCIL PROFILE
ARGYLL AND BUTE COUNCIL
Financial year 2013/14
1. Staffing
FTE (full time equivalent)
1
1
0.1
2. Data input
Local authority Database UNIFORM
Will interface with AMES be considered?
We have no intentions to consider implementation of Animal Health Enforcement System following the outcome of the
pilot. We will focus on developing a suite of animal health and welfare indicators through the Strategy Group, and
continue using our existing UNIFORM information management system
3. Work Load - Critical Control Areas (CCA)
a) with defined work patterns
Argyll and Bute Council Service Profile 13-14
Page 43
Number of officers
1 Senior Animal Health and Welfare Officer
2 Animal Health and Welfare Officer
Service Manager
Type of CCA
Market
No.
4
dedicated
markets, 3
market
companies,
4 draft sale
systems
3
1
Low throughput at Tiree, Mull and Islay
Moliegh, Oban
Approx 24
b) without defined work patterns
Type of CCA
No.
Ports
Minor ports and marinas. International catering waste registrations indicate approximately 50
Dealers
Hauliers
3
11
4. Total risk assessed premises including CCAs
According to information supplied by AHDO and risk assessment by local authority
Argyll and Bute Council Service Profile 13-14
Page 44
Slaughterhouses
Unique lairage area
reflecting geographic
nature of Argyll and Bute
Shows, sales and one-off
events
Operating pattern (markets) or throughput (slaughterhouses)
Oban and Dalmally operate throughout the year. Bridgend (Islay) has approximately 9
sales /yr. Tiree has 4-5 sales per year (some are 2 day sales). Caledonian Marts
operate draft sale on Islay and sometimes on Mull. Dumfriesshire and Cumberland
Farmers operated a tup sale this year.
The service has implemented the COSLA risk rating system with some minor amendments. This works well within Argyll
and Bute Council and is used to develop work programmes and direct the effective use of our resources.
No. of premises
(including 3(a) & (b)
above)
High Risk
78
Medium Risk
580
Low Risk
1209
Note: Figures accurate as of January 2013
Argyll and Bute Council Service Profile 13-14
Page 45
The frequency for programme interventions is:
High risk – annually
Medium risk – 5 years
Low risk- alternative enforcement strategy
APPENDIX I
Local Authority: ARGYLL AND BUTE COUNCIL
Service Plan for year: 01/04/2013 to 31/03/2014
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
1. Planning the Delivery of the Local Authority Animal Health Function
Analysis of critical control points by type, number,
days of operation, including:
• premises used for sales (e.g. auction markets
etc.)
a) This is detailed above in section 3 of the Service Profile.
b) The service plan has been discussed and greed with the AHVLA. For the first time, we have
agreed to add AHVLA interventions into the plan in section 11, demonstrating the joint working
arrangements which are in place between both agencies
• abattoirs/slaughter houses
Analysis of agricultural premises according to risk
Summary of staff engaged in Animal Health and
Welfare work
Outcomes 3 and 5
1.2 Annual
Service Plan
for delivery of
services in
Animal Health
and Welfare
Service Plan produced detailing levels of Service
Delivery for all activities detailed in this activity
framework, reflecting national and local priorities.
Annex C should be used as a template.
Outcomes 3, 4,and 5
Argyll and Bute Council Service Profile 13-14
The service plan is formally agreed by the Councils Regulatory Services Manager and Leads
Veterinary Officer with the AHVLA annually and formally approved by the Planning, Protective
Services and Licensing Committee.
Page 46
1.1 Profile of
Local Authority
area and
associated
animal health
and welfare
workload
Content and relevant outcome(s)
1.3 Risk
Assessment
Premises risk assessed in accordance with the
national risk scheme detailed in Section 4
Risk based inspection programme
Outcomes 1, 2, 5 and 6
Local Authority Planned Level of Service Delivery
a) All premises are rated using our revisions to the COSLA risk rating scheme and classed as
high, medium or low risk. They are them programmed for inspection based on our inspection
frequency
b) The programme for High Risk premises is notified to the AHVLA and SGRPID in an attempt to
share information and where possible, undertake joint visits. It also allows other agencies to
highlight specific issues which can be considered as part of the programmed visit. This is
consistent with the principle of better regulation, but where the other agencies are unable to
share their programmes, we will undertake our own work, as planned.
c) We plan to review the risk rating scheme in 2013-14
d) The interventions programme for 2013-14 will be identified and agreed with the Regulatory
st
Services Manager on the 1 April 2013. The current draft identifies the following interventions
although this is subject to change:
Argyll and Bute Council Service Profile 13-14
Page 47
78 high risk visits58 medium risk visits
25 primary production visits
42 Market interventions
30% of low risk premises: alternative enforcement
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
2 Training and Development
2.1 Training
for new officers
On-going
professional
development
Officers are authorised to enforce all relevant
legislation. All enforcement staff to hold recognised
qualification or have equivalent professional
experience
Time and resources allocated to keep up to date on
appropriate Animal Health and Welfare legislation,
codes of practice, guidance etc
Outcome 5
Argyll and Bute Council Service Profile 13-14
The target is 10 hours CPD for each officer
Page 48
It is recognised that in emergency situations i.e.
outbreaks of disease, there may be a need to call
upon non animal health qualified officers to assist in
carrying out animal health and welfare duties.
a) All animal health and welfare officers are authorised in accordance with the legislation. Their
level of authorisation is dependent upon their qualifications, training and competency
b) Two of our officers have a formal AHW qualification and all have a working knowledge of the
agricultural sector. A training programme is in place for the third officer and there is a formal
CPD system in place for all
c) In the event of emergencies, we will authorise other Regulatory Services staff to undertake
specific duties, subject to their skills (i.e. EHO’s may be involved in contact tracing, cleansing
and disinfection etc.)
d) We have a Continued Professional Development system in place for AHW officers to ensure
they maintain and their competency and are informed of developments etc. There is also an
annual Performance Development Review process which identifies training needs and
priorities
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
3. Licensing Activities
Zoo licensing
3.1
We will undertake the necessary work associated with licensed zoos within our area and respond to
st
any associated service requests As of 1 March 2013, there are 2 licensed zoos in Argyll and Bute
4. Education and advice to maximise compliance
4.1 Education
and advice
Guidance provided to businesses on all aspects of
Animal Health and Welfare for which Local
Authorities are responsible, including any
movement licensing requirements.
4.2 Proactive
activity
Outcomes 1, 2, 5 and 6
Targets for 2013-14 Complete 100% of high risk visits; resolve 85% of service requests
within 20 working days
Proactive involvement or lead in education and
training events with stakeholder organisations etc.
a) We provide information to the industry through a range of different activities:
a. Through the website or business information
b. Through “surgeries” at markets and other visits
c. On a one-to-one basis during inspections
d. Direct liaison with other partners including NFU, Food for Argyll etc.
e. Presentations and trade events
Joined up approach to education and advice
through liaison with the Scottish Government, Local
Government Regulation and Animal Health
Outcomes 1, 2, 5 and 6
b) Information displayed on website
Attendance at stakeholders/enforcement groups
c) We are an active member of the Animal Health and Strategy Group, and various liaison/panel
meetings across Scotland and the Framework Steering Group. In additional and at a local level
we have liaison group arrangements with the NFUS, SGRIPID, SSPCA and the Agricultural
Forum
Argyll and Bute Council Service Profile 13-14
Page 49
Delivery targets should be set in accordance with
individual Local Authority ‘charter’ response times.
a) Business advice available from officers during working hours and information readily available
on the website. There is also a generic email box for animal health enquires. AH&W business
advice available on Council website.
b) We have local indicators relating to service requests resolved within 20 working days and the
number of high risk inspections done within the due date. We are also in the process of
establishing a benchmarking club to develop common benchmarks between similar local
authorities to aid service improvement
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
5. Enforcement activities to maximise Animal Health and Welfare compliance
5.1 Attendance
at Critical
Control AreasLivestock
markets,
Sales, and
Assembly
Centres
Exact attendance levels and times
according to status of gathering
Outcomes 1, 2, 5 and 6
Argyll and Bute Council Service Profile 13-14
a) We have developed a market strategy to ensure that we are able to undertake our enforcement
duties within markets and this has been agreed with AHVLA and implemented in 2013-14. This
novel approach is likely to be considered as part of the Scottish review of market interventions
in 2013 following the national Market Baseline report.
b) The interventions required for each market is specific to each, given the outcome of its risk
assessment, and programmed into the services operational work.
Target:
We will measure our performance against this programme with target of 90% of the agreed
interventions programme for markets being completed
Page 50
Highly visible preventative enforcement presence.
Attendance at markets and other sales, and
Assembly Centres to ensure compliance, in
particular with:
• Biosecurity (vehicles, premises and people)
• Livestock identification
• Welfare
• Transport
• Licensing and record keeping
• Specific pre movement licensing
• All other relevant legislation
Content and relevant outcome(s)
5.2
Attendance at
Critical Control
Areas slaughter
houses
5.3
Attendance at
Critical Control
Areas Dealers/Agents
a) Attendance at slaughter house on request of OV or the Meat Hygiene Service or as a result of
particular intelligence that there is a problem outwith the responsibility of the OV.
Target: to respond to enquiries regarding slaughterhouse – 100%
Page 51
The MHS are
responsible for
enforcement and
Local Authorities
should liaise with
MHS with regard
to any need to
enter the
slaughterhouse
production area.
Attendance at slaughter houses (high and low
through put, red meat and poultry(white meat) in
liaison with MHS to ensure legislative compliance,
in particular with:
• Biosecurity (vehicles, premises and people)
• Livestock identification
• Welfare
• Transport
• Licensing and record keeping
• Specific pre movement licensing
• All other relevant legislation
Local Authority Planned Level of Service Delivery
Outcomes 1, 2, 5 and 6
Identification of Dealers and Agents
a) List of High Risk dealers and agents compiled in consultation with AHVLA
Visits/inspections to verify legislative compliance
b)
Outcomes 1, 2, 5 and 6
High risk dealer premises to be visited in terms of their risk rating
• Written report of non-compliance given at time of visit
• Major non compliances reported to relevant agencies
• Re-visits undertaken when actionable infringements occur
c) Businesses will be inspected in accordance with their risk rating or more frequently based on
local, regional and national intelligence or concerns
Argyll and Bute Council Service Profile 13-14
Content and relevant outcome(s)
5.4
Attendance at
Critical Control
Areas - Ports
Attendance at Ports to ensure legislative
compliance, in particular with:
• Biosecurity (vehicles, premises and people)
• Livestock identification
• Welfare
• Transport
• Import/export documentation
• All other relevant legislation
5.5
Attendance at
Critical Control
Areas - High
risk Farms
(Other than
dealers or
agents)
Visits/inspections to verify legislative compliance
Outcomes 1, 2, 5 and 6
There are no significant ports within Argyll and Bute Council although there is the movement of
livestock throughout the district by ferries and road.
To combat this we have:• Arrangements in place with CALMAC which regulates the transportation from livestock
from the islands
• We have a programme of two roadside checks planned with Strathclyde Police (soon to be
Scottish Police) in 2013-14. This will be augmented by vehicle inspections in markets
• We will support AHVLA, as requested and where resources permit, in respect of the
storage and disposal arrangement for animal by-products and international catering waste
at marinas and ports in a programme of joint working with AHVLA in 2013-14
a) All premises are inspected in accordance with the risk rating although more frequent
inspections may be undertaken where local knowledge or intelligence suggests possible AHW
issues. The inspection programme is developed and agreed with the Service Manager at the
beginning of every financial year and resources are allocated to meet this programme. The
programme is discussed with SGRPID to minimise the duplication caused by multiple
inspections and visits.
b) High risk premises to be visited annually. Written report of non-compliance given at time of
visit. Major non compliances reported to relevant agencies Re-visits undertaken where
appropriate
c) We have agreed with the AHVLA, that they would consider appropriate interventions for fish
farms and that a strategy would be discussed in 2013-14
Argyll and Bute Council Service Profile 13-14
Page 52
Outcomes 1, 2, 5 and 6
Local Authority Planned Level of Service Delivery
Content and relevant outcome(s)
Visits to verify legislative compliance.
5.6. Visits and
inspections to
other premises
Commercial hauliers
Farms (including own livestock vehicle)
Agricultural Shows and farm dispersal sales
Animal by-products premises including
Local Authority Planned Level of Service Delivery
Visits only undertaken to other premises on intelligence basis or as a result of another inspection
plan e.g. Primary Production visit plan.
Integrated primary production inspections are undertaken by AHW officers and the remit includes
animal health and welfare, food and feed hygiene.
Joint working arrangements are in place with AHVLS; SGRPID and the SSPCA.
Any other premises of livestock origin and
destination
All inspections are confirmed in writing
Outcomes 1, 2, 5 and 6
Roadside checks (in conjunction with police)
Police led multi agency roadside checks
local authority led checks for animal health and
welfare compliance only (including co-ordination
with adjacent Local Authorities)
a) We have joint working arrangement with the police for roadside checks although inspections
are undertaken of vehicles within the markets. These arrangement are unlikely at this stage to
be affected by the new single Scottish Police Service
b) In conjunction with police
c) Only on basis of intelligence.
National exercises and operations
Target; Joint roadside checks to be undertaken in conjunction with the police in 2013-14.
Outcomes 1, 2, 3, 4 and 6
Argyll and Bute Council Service Profile 13-14
Page 53
5.7 In transit
checks
Content and relevant outcome(s)
5.8 Postal
record recall
checks (if
carried out) on
livestock
premises
Postal recall checks and verification according to
risk
Local Authority Planned Level of Service Delivery
There are no proposals to undertake any postal recalls unless intelligence indicates that such
activity is necessary. This has been agreed with AHVLA who advise that this work is not normally
undertaken in Scotland
Non responses subject to follow up action as
appropriate (including, if necessary premises visit
inspection)
Outcomes 1, 2, 5 and 6
Checks on vehicles to ensure cleansing and
disinfection carried out at premises other than
where they have delivered livestock
Outcomes 1, 5 and 6
a) On-going routine checks at livestock market
b) Specific checks will be made on vehicles where targeted intelligence identified issues and
concerns or where disease is suspected
c) Alternative enforcement and follow-up visits will be made to respond to any issues identified
through market audits
Target; interventions undertaken subject to our market intervention plan, concerns or
intelligence
Argyll and Bute Council Service Profile 13-14
Page 54
5.9 Vehicle
biosecurity –
cleansing and
disinfecting
compliance
Content and relevant outcome(s)
5.10 Out of
operating
hours checks
Checks out of normal specified operating hours or
subsequent days for:
Markets
Slaughter houses
Premises used for collection of animals for
slaughter or for further rearing or finishing
Local Authority Planned Level of Service Delivery
These will be inspected in accordance with their risk categorisation and in response to service
requests or concerns. The market strategy requires work out with core hours (e.g. weekends etc.)
Outcomes 1, 2, 5 and 6
Emergency interagency contact regarding disease
and other enforcement incidents
Outcomes 1, 2, 3, 4 and 6
Argyll and Bute Council Service Profile 13-14
a) Emergency out of hours contact procedure in place and notified to agencies
b) Out-of-hours arrangements through Civil contingencies Manager or Regulatory Services
Manager/Senior Animal Health and Welfare Officer
c) Updated annually or as notified
d) Contingency plans have full details of out-of-hours arrangements
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5.11 Stand by
and on call
arrangements
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
6. Partnership working and intelligence driven enforcement
6.1 Identified
Infringements
Identified breaches of legislation, including
biosecurity, licensing, welfare, livestock
identification, standstill breaches, illegal imports, by
products, and other disease control work.
.
a) We will respond to service requests received from the general public, industry and other
agencies
b) Investigated and appropriate action taken in accordance with our Enforcement Policy
c) Follow up checks on suspected irregularities identified on SAMU, BCMS, by
SGRIPID,SSPCA and AHVLA
Irregularities found on documentary checks
followed up
Outcomes 1, 2, 5 and 6
Provision and collection of Intelligence Information
Outcomes 1, 2, 5 and 6
We use the UNIFORM information management system to record all inspections, service requests
and enforcement activity associated with this work. The system provides management information,
and generates inspection programmes etc. It is effective in terms of work planning and reporting
and is shared by environmental health colleagues
In addition, we use other stand-alone systems for primary production visits (SCORS) and utilise
the SCOTEID national database for cattle and sheep movements, as an intelligence source to
influence our interventions.
6.3 Intelligence
led actions
Infringements or suspected infringements reported
from external enforcement sources or identified by
use of data interrogation or intelligence sources;
members of the public/complaints
Outcomes 1, 2, 5 and 6
Argyll and Bute Council Service Profile 13-14
Liaison and other group, together with peer relationships, provide an opportunity to share
intelligence in accordance with Data Protection requirements, and to develop collaborative and joint
working.
a) All enforcement action is taken in accordance with the services enforcement policy and
procedures. These are revised annually or more frequently, as required
b) Formal notices are reviewed by the officers line manager prior to service by the officer
c) All formal reports to the PF are approved by the Regulatory Services Manager
d) A formal RIIPSA authorisation process is followed where directed surveillance may be
required
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6.2
Intelligence /
Information
and systems
Content and relevant outcome(s)
6.4 Cross
border and
multi-agency
working
Assessment and communication to interested
parties of cross cutting issues
Research/intelligence led activities including
workshops
Joint investigations/exercises/initiatives
Mentoring arrangements
Local Authority Planned Level of Service Delivery
a) Proactive work with other local authorities
b) We manage and maintain the animal health incinerator for anthrax cases which is a shared
resource between 8 local authorities
c) Membership of AH&W Regional and National Panels. Taking part in their cross cutting
projects.
d) Member of the National Framework Steering Group
e) Members of AH&W Regional and National Panel as well as of AH&W Strategy Group
f) We have local arrangements in place with SGRPID to reduce multiple visits and promote
joint working; and have excellent working relationships with the SSPCA
g) We have mutual support arrangements agreed with other neighbouring local authorities
Outcomes 1, 2, 3, 4 and 5
7.1 Animal
Health and
Welfare
Management
and
Enforcement
System
(AMES)
7.2
Management
information
Entry of data onto electronic information
management system recording local authority
enforcement activities, results and actions.
We have a wide range of performance indicators relating to inspections and the resolution of
service requests. These are reported quarterly across the Council via Pyramid, and we are working
with other LA’s to develop a benchmarking club so we can compare information with other similar
authorities
Recording of data on infringements
Outcomes 1, 2, 3, 4, 5 and 6
Collation of management information data for
internal use and provision to the Scottish
Government and Animal Health,
Outcomes 3, 4 and 5
Argyll and Bute Council Service Profile 13-14
Timely provision of information in particular submission of statutory returns
Page 57
7. Post enforcement reporting and Animal Health and Welfare Management and Enforcement System (AMES) data
entry activities
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
8. Contingency planning and emergency action
8.1
Animal Health,
Scottish
Government ,
COSLA and
local authority
emergency
preparedness
Planning and contributing to emergency
preparedness plans with Animal Health, Scottish
Government and other agencies as appropriate
8.2 Testing
and Training
Testing, training, practising and evaluating activities
in relation to the emergency plan
We have a generic Animal Health Disease Plan which is approved by Council and updated
annually
We will review contact arrangements within plans annually
Outcomes 1, 3, 5 and 6
Target Review generic animal health disease plan annually; participate in regional and
national exercises, as appropriate
Outcomes 1, 3, 5 and 6
8.3
Emergency
Action
Provision of full emergency range of services under
the emergency plan, when disease emergency
declared by the Scottish Government
Outcomes 1, 3, 5 and 6
Argyll and Bute Council Service Profile 13-14
This would be a priority incident and the service would respond in accordance with the designated
plans.
Page 58
Target Review We will participate in regional and national exercises, as appropriate. At a local level, we will
test our own arrangement every 2 years
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
9. Additional Activities
9.1 National
priorities
Provide details in Service Plan (Annex C) of
identified priorities as agreed with AHVLA and the
Scottish Government
Outcomes 1, 2, 5 and 6
The general outcome are to:
• effectively reduce the risk of animal disease incursion and spread, thereby protecting public
and animal health
• improve animal welfare
• meet the objective of Delivering and enforcing standards, of the Animal Health and Welfare
Strategy; and the Scottish Government’s objective ‘well treated and healthy farm (and
domestic) animals
Page 59
Argyll and Bute Council Service Profile 13-14
Content and relevant outcome(s)
9.2 Regional
priorities
Agree regional priorities, with AHVLA at regional
animal health and welfare panel meetings for
consideration in annual service planning
Outcomes 1, 2, 5 and 6
As determined by local authority in agreement with
AHVLA
Annual service meeting with AHVLA is held every six monthly to review the service plan. There are
other ad-hoc meetings as appropriate.
Regional priorities
a)
Strategy
AHVLA will visits markets in Argyll and Bute to support the Councils Market
b)
AHVLA to consider appropriate interventions in respect of animal health and
welfare at fish farms in association with SEPA to make LA aware of any developments,
identified service demands.
c)
AHVLA to undertake specific work in respect of the storage and disposal of
animal by-products and international catering waste, working closely with Argyll and Bute
Council
d)
AHVLA to support LA officers in addressing on-farm/market and transport
welfare issues within the response time for both organisations (48hr except where geographical
/meteorological or transport issues prohibit this response time).
The local prioritise for 2013-14 are:
(i)
Extend market strategy with interventions by AHVLA incorporated within the
programmed interventions
Outcomes 1, 2, 5 and 6
(ii)
On Farm Welfare
Argyll and Bute Council Service Profile 13-14
Deliver the alternative enforcement strategy
Page 60
Local priorities
Local Authority Planned Level of Service Delivery
Content and relevant outcome(s)
Local Authority Planned Level of Service Delivery
1(a)
Authorisation
1b) Response
Authorisation of inspectors under part 2 of the
Animal Health and Welfare (Scotland) Act 2006
3 officers
Response to farm welfare complaints received from
a member of the public or another agency
The service standard is that service requests will be resolved within 20 working days and we have
a target of 85% in 2013-14.
Service requests are prioritised in accordance with our rating scheme and high priority (Priority 1)
requests are visited within 2 working days.
1(c)
Enforcement
Action
Where an animal’s welfare is being seriously
compromised immediate enforcement action should
be taken.
Where an animal’s welfare is being seriously compromised immediate enforcement action will be
taken working with partner agencies
All enforcement action will be proportionate, risk based and in accordance with our
enforcement policy
1(d) Follow up
where
complaint
received
Follow up visits to premises against whom a welfare
complaint is received
If necessary and in conjunction with VO the premises will be re-visited within an appropriate period
of the initial visit
Argyll and Bute Council Service Profile 13-14
Page 61
The response to all service requests is proportionate to the nature of the complaint and may involve
appoint inspections or a joint investigation with environmental health staff, police, AHVLA and/or
SSPCA
Content and relevant outcome(s)
1(e) Follow up
where
improvement
notice is
served
Local Authority Planned Level of Service Delivery
Monitoring visits carried out during the compliance period appropriate to the severity of the
complaint
Revisit carried out within 10 working days of the end of the Compliance Period specified in the
Notice or sooner dependent upon the severity of the complaint
Page 62
Argyll and Bute Council Service Profile 13-14
Page 63
APPENDIX II – SERVICE ASSESSMENT AGAINST FRAMEWORK
Criteria
Activity
Minimum
Standards and Status
Good Practice
Better Practice
1.1 Profile of Local Authority
ABC
1.2 Annual Service Plan
AB C
1.3 Risk Assessment
AB C
2.1 Training of Officers
AB C
4.1 Education + Advice
ABC
4.2 Proactive Activity
ABC
5.1 Enforcement Markers
novel approach
5.2 Slaugherhouses
ABC
5.3 Dealers/Agents
AB C
5.4 Ports
A BC
5.5 High Risk Farms
AB C
5.6 Visits + Inspections to Other Premises
AB C
5.7 In Transit Checks
AB C
5.10 Vehicle Biosecurity
ABC
5.11 Out Of Hours Operating
AB C
5.12 Standby/On Call
AB C
6.1 Partnerships Legislation Breaches
ABC
6.2 Collection of Intelligence
AB C
6.3 Engagement with Others
ABC
6.4 Cross Board/Multi Agency Working
ABC
7.1 AMES Reporting
ABC
7.2 Reporting of Activities
ABC
8.1 Planning for Emergencies
AB C
8.2 Testing + Training
ABC
8.3 Emergency Action
ABC
9.1 Service Plan with National Priorities
ABC
9.2 Regional
ABC
9.3 Local
ABC
Key.
Dark shaded indicates the level of standards available for each criteria
(i.e. minimum, best and good practice)
Light shaded (ABC) indicates Councils attained level of standard
27
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Page 65
Agenda Item 6
Argyll and Bute Council
Development Services
Delegated or Committee Planning Application Report and Report of handling as
required by Schedule 2 of the Town and Country Planning (Development Management
Procedure) (Scotland) Regulations 2008 relative to applications for Planning Permission
or Planning Permission in Principle
Reference No:
Planning Hierarchy:
Applicant:
Proposal:
Site Address:
11/01066/MFF
Local Development
Lakeland Marine Farms Ltd.
Relocation of Ardmaddy fish farm - comprising 12 No. 100m
circumference cages plus installation of feed barge
Port Na Morachd, Seil Sound
DECISION ROUTE
Local Government Scotland Act 1973
(A)
THE APPLICATION
(i)
Development Requiring Express Planning Permission
• Formation of Marine Salmon Fish Farm comprising 12 No. 100m circumference
cages, walkways, mooring grid and associated lines,
• Installation of feed barge;
• Installation of underwater lighting.
(ii)
Other specified operations
• Servicing from existing shore bases at Loch Craignish and Croabh Haven;
• Removal of 18 No. 24m x 24m steel cages from existing site at Ardmaddy North
and relinquishment of lease.
(B)
RECOMMENDATION:
It is recommended that permission be granted subject to:
(C)
i)
a pre-determination hearing be convened in response to the number and
complexity of the representations received;
ii)
the conditions and reasons set out in this report.
CONSULTATIONS:
Scottish Environment Protection Agency (27.07.11 & 11.12.12) – In order to address
the likelihood of significant effects upon the Firth of Lorn Special Area of Conservation
(SAC) SEPA will require to undertake a Habitats Directive ‘appropriate assessment’ as
part of its Controlled Activities Regulations (CAR) licence application, and until this
Page 66
process is completed it is not possible to say whether the biomass proposed will be
licensable under CAR. Subsequent response in 2012 confirming that a CAR licence
has been granted and supplying a copy of the ‘appropriate assessment’ undertaken by
SEPA in support of that consent.
Comment: Pollution control is exercised by SEPA and government advice to planning
authorities is not to seek to use the planning process to duplicate other regulatory
regimes. Where multiple consents are necessary there is no prescribed order in which
they should be obtained. However, in view of the importance of potential pollution
effects upon protected habitats and species in this particular case, and given the large
numbers of representations to the planning application being related to pollution issues,
the applicants were advised by planning officers to agree to this planning application
being held in abeyance, in order to allow them to pursue a CAR licence application in
advance of the determination of the planning application, so that that the consequences
of pollution could be assessed by the appropriate agency and conclusions reached,
outwith the planning process. An application was duly submitted and processed by
SEPA, who undertook a Habitats Regulations ‘appropriate assessment’ in the
consideration of that application. In view of the number of adverse third party
representations to the CAR licence application, the intended decision by SEPA was the
subject of review by Scottish Ministers before being issued. No intervention in the
intended course of action arose as a consequence of this and a CAR licence was duly
granted.
Scottish Natural Heritage (28.08.11 & 26.02.13) – in view of the likely significant
effect on the Firth of Lorn Special Area of Conservation the planning authority is advised
to undertake an ‘appropriate assessment’ having regard to the conservation objectives
of the SAC addressing the transport of organic wastes and chemotherapeutants from
the site. Further comment will be made once the AA has been concluded.
In terms of European protected species the proposal has the potential to affect otters
and cetaceans. It is not expected that the site would affect otters significantly. The
deployment of acoustic deterrent devices to deter seals could have consequences for
porpoises as whilst research indicates that they will avoid areas where ADD’s are in
operation (but will return once they are switched off), continuous operation could have
the effect of excluding them from the Sound. SNH consent should therefore be required
for the deployment of ADD’s at this location. Whilst the faunal analysis of the seabed
shows a relatively diverse and abundant community no benthic impacts prejudicial to
national interests have been identified. Predators such as seals, otters and pisciverous
birds are common in this locality. The applicant considers that double nets are
impractical in this location due to strong tidal currents and SNH concurs that tensioned
nets with anti-chafe panels as employed at many other sites will be sufficient to
minimise risk of escapes. The applicant’s predator control plans and risk assessments
require some updating (subsequently completed). Whilst there are no salmon rivers
within 15km, sea trout will frequent the area year round. Sea lice treatments to SSPO
Code of Good Practice Standards and operation in accordance with the local Farm
Management Agreement will minimise impacts on wild fish, as will the intended use of
well boats for chemical treatments, rather than the more traditional tarpaulin method
employed at the existing site. White cluster anemone is present in the vicinity of the site
and the SEPA CAR assessment should address consequences for this Priority Marine
Species.
In terms of landscape impacts as the proposal does not affect any national designations
SNH has no objections on landscape, visual or recreational/amenity grounds. Localised
impacts could be reduced by repositioning the barge to the south end of the site where it
would be better screened by higher ground on Torsa to the west. Whilst the area is
frequented by tour boats, yachts and kayaks and the development will give rise to
Page 67
localised impacts these are not considered to be such that they will significantly affect
the overall experience of the Sound and the wider Firth of Lorn.
Following the production of the Council’s draft ‘appropriate assessment’ SNH has
confirmed its satisfaction with the content.
Comment: The option of relocating the feed barge to the southern end of the site has
been resisted by the applicants, as for operational reasons a barge location at the least
exposed end of the site is preferable as it presents less risk to containment in the event
of the barge moorings being compromised in storm conditions. The applicants have
however agreed to reduce the scale of the barge from 26m x 18 m to 14m x 10m in
order to lessen its visual impact and amended plans to that effect have been submitted.
Marine Scotland Science (02.08.11) – No objection. Note the intention to use well
boats for sea lice treatments and the potential to use Wrasse as a supplementary
means of lice control. There are no major Atlantis salmon fisheries within 15km so wild
salmonids in this area are likely to be marine phase sea trout throughout the year and
migrating salmon. Provided the site is operated in accordance with the existing Farm
Management Agreement for the area, in accordance with the SSPO Good Practice
Guidelines and the necessary steps are taken to control lice numbers and to maintain
equipment to minimise risk of escapes, then impacts upon wild fish will be minimised. It
is recommended that it should be a condition of any consent that the existing site at
Ardmaddy North is relinquished.
Argyll & District Salmon Fishery Board (11.07.11) – No specific objections but it is
noted that the development involves a significant increase in biomass and that it would
be preferable for this to be maintained in the initial period following relocation to enable
the applicant to demonstrate that SSPO Code of Good Practice sea lice levels can be
achieved. In the event of an approval, it should be a requirement that the current site be
closed and the lease surrendered.
Historic Scotland – response awaited.
Northern Lighthouse Board (08.07.11) – no objection but advice given as to
navigation marking and lighting requirements.
Royal Yachting Association – have indicated verbally that they have no comment to
make in respect of the planning application and that they will reserve any comment for
the Marine Licence application as and when that is submitted.
Clyde Fishermen’s Association (21.07.11) – object to further development of the
wider fish farming industry in general and this application in particular due to the
adverse consequences of pollution in the marine environment and the general
unsustainability of farming fish.
Mallaig & North West Fishermen’s Association – no response
Council’s Marine & Coastal Manager (10.08.11) – the scale of the existing and
proposed sites are similar in terms of surface equipment area and the characteristics
and designations of the landscape are similar for both sites although the proposed site
occupies a more confined section of the sound, where its visual presence may be
increased. The RYA sailing route hugs the west side of the channel and the proposed
site does not conflict with this. The Marine Licence process will address navigational
issues. Risk to wild salmonids is unlikely to significantly increase if the Farm
Management Agreement continues to be adhered to and the proposed mitigation is
implemented, given that Marine Scotland considers the modelled availability of sea lice
Page 68
treatment to be sufficient for the biomass proposed. SEPA’s CAR licence process will
include consideration of potential effects on the Firth of Lorn SAC. Three seal haul outs
are within 2km although the applicant’s three sites around Shuna are closer to larger
haul outs. The use of Acoustic Deterrent Devices in narrow water bodies may restrict
the use of the area by cetaceans and advice should be sought as to whether a licence
from SNH would be required for their deployment.
Council’s Biodiversity Officer (25.07.11) – no objection but further comment sought
about potential effects upon marine species. Concern that the proposal will reduce the
width of the channel available for dolphin and porpoises.
Scottish Wildlife Trust (26.09.11) – objects to the development on the grounds that in
the absence of an Environmental Impact Assessment there is insufficient information to
enable the required Appropriate Assessment in terms of implications for the Firth of Lorn
Special Area of Conservation, and therefore the process is unsound. The SAC is of
international conservation importance and the wildlife it supports is of tourism value. For
development to proceed, it must be concluded beyond reasonable scientific doubt that
the implications for the protected rocky reef habitat and the species it supports will not
have an adverse impact on the integrity of the SAC. Failure to employ double nets and
the consequent need to employ acoustic deterrent devices or the licenced shooting of
seals, would not lead to seal shooting as a ‘last resort’, as legislation requires. Porpoise
dolphin and otter use the sound regularly and would be disturbed by the deployment of
ADD’s. Local wild salmon and sea trout stocks have collapsed in recent years and sea
lice associated with the development will be likely to adversely affect these protected
species. The transport of organic waste and chemotheraputants from the site to the
SAC would be contrary to its conservation objectives and would adversely affect the
integrity of the designation. Given the presence of rock reefs and complex tides,
conventional deposition modelling is not an appropriate method for predicting likely
effects. Priority Marine Features such as white cluster anemone to the north of the site
are likely to be affected reducing their value as dive sites contrary to the interests of the
tourism economy.
Kilninver & Kilmelford Community Council (14.02.13) – have objected to the
proposal on the grounds that the development will cause noise light and water pollution,
and lead to rubbish being washed up on local beaches. It is also considered that the
development will disadvantage the local tourism economy and could pose a threat to
navigation and the interests of wild fish. The community support smaller scale
aquaculture developments but consider that this is too prominent and conspicuous site
for the scale of development proposed.
Seil & Easdale Community Council (04.08.11) – have objected to the proposal on the
grounds that the area is one of scenic value and of importance to yachts, tour boats and
other recreational craft, which collectively support the local tourism economy. The
presence of the farm would narrow the channel and make it more difficult to avoid the
rocks off Torsay Island (sic). There is concern locally that the development will not be in
the interests of wildlife tourism, and also that consent for additional pollution is being
sought given the expense of the Seil waste water treatment scheme. It is recognised
that the Council has to balance economic arguments with the environmental disbenefits
of the proposal, but that in this case protection of the environment should prevail. If the
development proceeds, consideration should be given to reducing projection out into the
channel, reducing the impact of the feed barge, using double netting as opposed to seal
scarers and control over lighting.
Luing Community Council (02.08.11) – object in terms of concerns they have as to
the effects of the proposal upon wildlife, tourism, sailing and recreational activities due
to pollution in the vicinity of Luing and the Firth of Lorn Special Area of Conservation.
Page 69
Luing is heavily dependent upon tourism which is a key provider of employment on the
island unlike fish farming. They urge that an environmental impact assessment and
appropriate assessment should be used to inform the decision.
(D)
HISTORY:
The site benefits from a Crown Estate lease for a mussel farm (AR-3-6-17) although the
site is not currently equipped. No objection was raised by the Council to that
development (03/00843/MFF).
A Crown Estate lease is in place for a salmon farm to the north of the site at Ardmaddy
North (AR-3-6-6). This is currently equipped by 18 No. 24m x 24m steel cages.
The application site benefits from a CAR licence CAR/L/1099909 granted in December
2012.
It is intended that the proposal will supersede the shellfish site and that the lease for
nearby fin fish site, which is also in the control of the applicants, would be relinquished
and the equipment removed, in the event that this larger replacement farm at Ardmaddy
South is consented.
(E)
PUBLICITY:
The proposal has been advertised in the local newspaper (14.07.11 and 25.08.11) with
the publicity periods having expired on 15.09.11.
(F)
REPRESENTATIONS:
(i) Representations received from:
Objections to the proposal have been received from 814 third parties along with
8 supporters and 2 neutral representations. Names and addresses of those having
submitted representations are listed in an Appendix this report. The grounds of
objection and support are summarised below. It should be noted that a very high
proportion of the objections take the form of standard template letters and e-mails.
Support for the proposal
•
Aquaculture is an industry of the future and regulation in Scotland is amongst the
highest in the world;
•
Fish farming is a valued component of Argyll’s and Scotland’s economy providing
opportunities for growth in a region where other opportunities are limited;
•
The development presents opportunity to maintain or create jobs, both directly and
indirectly;
•
Fish farming produces a valuable product in the global market place, is one of our
few export success stories and should be supported;
•
The unscientific clichés advanced by objectors are misleading and inaccurate.
When reviewing public comments please remember that many, including young
people, are dependent on the aquaculture sector.
Page 70
Objections to the proposal
Application documentation and procedure
•
The scale of the site relative to the existing site has been misrepresented by the
applicant who has advanced it as a reduction whereas in practice it represents an
enlargement. It is requested that the location of the site should be marked by buoys
for the purposes of any committee site inspection;
•
The Planning Authority have described the proposal as a relocation of an existing
site whereas it is actually a new enlarged site. It cannot be legitimately regarded as
a relocation given the difference in scale;
•
The applicants refer to the site having an existing use as a mussel farm whereas
the site is not in use and has not been in use previously for this purpose;
•
The application ought to have been accompanied by an Environmental Impact
Assessment;
•
The application ought to be subject to ‘appropriate assessment’.
Comment: The application has been described by the applicant as a relocation as the
intention is that it should be a replacement for their existing fish farm at Ardmaddy.
Likewise, it was advertised by the Planning Authority as a ‘relocation’ so as not to
mislead interested parties into believing that a second farm was proposed in the locality
of the existing site. In order to clarify that the proposed development is intended to be
an enlarged facility (rather than a straight replacement for the equipment at the existing
site), the proposal was advertised a second time, in order to make entirely clear the
nature of the equipment proposed.
The aggregate area of the surface equipment is a reduction in that at the existing site,
although the extent of the overall surface area of the site is greater, as circular cages
have larger intervening areas of water than the more compact arrangement of square
pens found at the existing site.
Although the site has not been equipped for mussel farming it maintains a Crown Estate
licence for such and would be capable of being so used without the requirement for
further consent. The existence of the licence and the ability to occupy the site in
accordance with the terms of the lease is a material planning consideration.
The proposal was ‘screened’ for the requirement for an Environmental Impact
Assessment by the Planning Authority in advance of the application being submitted.
Following consultation with interested bodies such as SEPA, SNH and Marine Scotland
it was determined that as a relocation and enlargement of an existing site, an
Environmental Statement would not be required in this particular case.
To satisfy the requirements of the Habitats Regulations, an ‘appropriate assessment’
has been carried out by the Planning Authority drawing upon the conclusions of the
appropriate assessment undertaken by SEPA in the processing of their CAR licence.
This appears at Appendix B to this report.
Objections founded on planning policy considerations
•
The development would be harmful to a designated Area of Panoramic Quality and
the Firth of Lorn Marine Consultation Area which are designations intended to
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protect the local environment.
Comment: Consideration of the effect of the development on the landscape and
seascape of Seil Sound is required in the context of that associated with the current fish
farm equipment. Local Plan policy LP ENV 10 accords the scenic qualities of the area
regional importance. However fish farms are commonly located in scenic designation in
Argyll, including National Scenic Areas which are accorded higher status in landscape
terms. The development plan status of the area is not such as to preclude development
but requires careful consideration of the landscape implications of development. The
Firth of Lorn Marine Consultation Area is one of biodiversity interest prompting
consultation with Scottish Natural Heritage. It is not a development plan designation
which presumes for or against development.
Objections related to pollution considerations
•
The doubling of biomass will increase the problems presented by the existing farm
and will threaten sensitive marine ecosystems. Sites of this scale should be
located further offshore and inshore sites should be operated at reduced stocking
densities with enhanced containment;
•
The site will produce large quantities of faecal waste well in excess of the produced
by the local community and this should be considered in connection with that
produced from consented fish farm sites in the area in terms of its cumulative
consequences for the environment;
•
The proposal will lead to excesses of nitrates, phosphates and other pollutants will
contribute to a return to inappropriate levels of pollution in the Sound (in part
addressed by the Seil wastewater treatment works). Given the £11m spent on
upgrading the sewage treatment system for the small community at Seil in order to
improve water quality in Seil Sound, it is perverse to countenance such an
additional polluting form of development.
•
Although a CAR licence has been granted by SEPA, they do not have the
resources to regularly monitor sites so the industry is largely self-regulating which
is worrying. There is reason to suspect that SEPA’s conclusions were flawed being
based on the application of a standard computer model which may not relect the
specific local conditions.
•
The applicants existing site has in the past been graded ‘unsatisfactory’ due to
impacts on the seabed extending beyond SEPA’s allowable zone for deposition
about the cages. Whilst the applicant and SEPA consider that the new site exhibits
better characteristics this conclusion relies on modelling which is not suited to
contained stretches of water with wide variations in speed and direction. As
modelling did not appear to represent actual experience at the existing site, there is
doubt about its reliability here.
•
The means by which mass and routine fish mortalities are to be disposed of has
not been addressed as part of the application;
•
The applicants have in 2006 previously pleaded guilty and have been fined £1000
for overstocking a site at Shuna.
Comment: Concerns regarding the polluting effects of development and the associated
consequences for habitats and species appear to be the principal grounds for objection
to the application. Although there is multiple consenting regime applicable to fish
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farming, there is no prescribed order in which those consents should be obtained.
Given that these concerns related to issues controlled by SEPA under separate
regulation, and having regard to the government cautioning planning authorities against
the improper duplication of other consenting regimes, it was considered appropriate in
this case that these matters of public concern be addressed in the first instance via a
CAR licence application, in order to confirm the consentability of the development from
a pollution control perspective before going on to determine the planning application
with reference to those matters material to the application. It should be borne in mind
that part of the driver for this application is to move operations away from the site at
Ardmaddy North to a location which is more favourable from a SEPA pollution control
point of view.
The applicants have concurred with this approach, and further to extensive public
representation to the CAR licence application which followed, following review of the
matter by Scottish Ministers at the end of 2012 a CAR licence was subsequently issued
by SEPA. That consent permits maximum biomass to be held on the site and licences
permissible quantities of chemical treatments for use at the site. Although third parties
continue to express doubt as to the reliability of SEPA’s conclusions in the matter, the
granting of the CAR licence is a matter of record and its validity cannot be questioned
as part of the adjudication of this planning application. SEPA has addressed the
capacity of the receiving environment to absorb the cumulative impact of multiple fish
farm sites and the associated consequences of designated habitats and species as part
of its assessment of the CAR licence application and has undertaken an ‘appropriate
assessment’ relative to the pollution consequences upon the nearby Firth of Lorn SAC.
Reference is made to the apparent conflict between the additional pollution associated
with this proposal and the costly waste water improvements implemented at Seil. These
were borne out of European obligations upon Scottish Water and were driven by
problems related to bacterial levels affecting shellfish waters, not by nitrogen or
phosphorous enrichment. Human waste and fish farm waste are not therefore directly
comparable in terms of their effects on the marine environment.
The disposal of fish mortalities on a routine basis or in the event of mass mortalities is
not subject to planning control. This is an operational matter for the applicants and is
regulated by SEPA (as waste) and by the Council’s animal welfare officers (animal byproducts). Typically, small scale mortalities are dealt with by way of incineration locally
with larger quantities being disposed of by specialised contractors at sites licenced to
handle this category of waste.
The track record of the applicants in the operation of other sites is not a material
planning consideration. Infringement of the terms and conditions of site licences is a
matter for SEPA to enforce as necessary.
Objections in respect of marine and nature conservation interests
•
The site will give rise to adverse consequences for wild salmonids, common and
grey seals and cetaceans and would therefore be contrary to the interests of
biodiversity;
•
The site is located too close to the Firth of Lorn Special Area for Conservation and
the seal haul out in Cuan Sound;
•
Disrespect for the marine environment to the detriment of marine life and its habitat
shows a lack of human compassion;
•
The use of Acoustic Deterrent Devices to scare predators away will also affect
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cetaceans, such as the porpoises which are often seen in the Sound. These are
protected by legislation and distress and adverse effects upon their hearing cannot
be ruled out. The use of locally triggered devices over short periods could still pose
a problem in that regard;
•
Failure by the applicants to employ double netting presents prospect of wildlife
entanglement, presents greater risk of escapes to the detriment of wild fish and
leads to the unnecessary use of seal scarers and avoidable seal shooting.
Development which poses a threat to seals and their pups ought to be rejected;
•
The Seal Protection Action Group opposes the shooting of seals and believes that
non-lethal predator strategies should be adopted;
•
The Salmon & Trout Association objects on the basis that the development is likely
to have an adverse impact upon migratory salmon and on sea trout as a result of
sea lice propagation and escapes of farmed fish. No expansion of production
should be allowed unless closed containment units are employed;
•
As an ex local fisherman I have experienced the negative impact of fish farm
development on the environment over the last twenty years and development of
this type should be located further off shore;
•
The developer should be required to underwrite independent monitoring of affected
ecosystems;
•
There is evidence of chemical treatments at fish farms proving harmful to shellfish
populations.
Comment: The consequences of the presence and operation of the site upon marine
habitats and species are clearly important issues for third parties, arising in part from
the pollution consequences of development, but also from other matters such as sea
lice propagation from farmed to wild fish, risk of escapes, deployment of acoustic
deterrent devices and the prospect of seal shooting. Neither Scottish Natural Heritage,
Marine Scotland nor the District Salmon Fishery Board have raise objections to the
proposal on nature conservation grounds. The Habitats Regulations ‘appropriate
assessment’ found at Appendix B has concluded that the proposal will not affect the
integrity of the nearby Firth of Lorn Special Area of Conservation, which supports the
conclusion reached by SEPA in their assessment of the preceding CAR licence
application.
The consequences of the development for cetaceans and seals is clearly an emotive
issue. The applicant’s experience is that the tensioned netting system proposed at this
site will provide adequate containment and protection against predators; a position
which is accepted by SNH. It reflects current industry practice across Scotland and the
applicant’s practice at other sites in Argyll including sites in proximity to seal haul outs.
The applicants do not routinely use acoustic deterrent devices (ADD’s) and currently
have none deployed on their sites across Argyll. Only one of their sites has been fitted
with ADD’s in recent years and that was for a temporary period as part of a university
research project. However, in order to secure ‘Freedom Foods’ accreditation the ability
to deploy ADD’s as an option is required as it is necessary to demonstrate that in the
event of persistent attacks by a rogue seal, all non-lethal methods have been employed
in preference to recourse to seal shooting. SNH have requested a condition requiring
details to be approved of the type and means of deployment of ADD’s should they
become required at some point in the future. In terms of seal shooting, this is licenced
by Marine Scotland and is not a material planning consideration. Annual returns to the
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Scottish Government indicate that in 2012 one seal was shot at the applicant’s existing
site at Ardmaddy. No seals have been shot at that location this year to date.
In terms of wild fish, the site is not close to important salmon rivers, although will be
subject to the presence of salmon in the migration season and sea trout on a year
round basis. The view of Marine Scotland is that provided the applicants adhere to the
Scottish Salmon Producer’s Organisation ‘Code of Good Practice’ (it is a requirement to
demonstrate compliance to maintain membership) and treatment is available in
sufficient quantities to control sea lice to CoGP standards, then the interests of wild fish
should be adequately protected. Given that a CAR licence has already been granted it
is already known that sufficient licenced treatments are available to the applicants at
this site. The applicants propose to use a combination of in-feed treatments and wellboat treatments. The latter are to be employed in preference to net shallowing and in
situ treatment, and this will improve efficacy and reduce the quantities of pollutants
released into in the marine environment.
Objections in relation to landscape, visual and amenity considerations
•
The height of the net structure above the cages and the installation of a concrete
feed barge give the development an industrial appearance;
•
This development is proposed in a sensitive area of natural beauty where the
barge, underwater lighting and the extent of the mooring area will impair views. It
would be a dereliction of duty to sacrifice natural beauty to commercial interests;
•
The south east coast of Seil Sound is unspoiled and identified by SNH as Craggy
Coastline. There is a long established walking route from Ardmaddy to Loch Melfort
which affords magnificent views. Development of this nature, which would not be
countenanced on land, would be an act of environmental vandalism;
•
Lighting will be intrusive given the absence of light sources in the area and the fact
that indirect glow will affect a much wider area dependant on atmospheric
conditions, even if the direct effects of light are localised or not significant at sea
level;
•
Noise from the feed barge generator would be intrusive in an area of low ambient
noise, particularly as it would operate at night as well as during the day. Low
frequency noise would be propagated long distances across open water. Generator
noise from the site at NW Shuna can be heard at Toberonochy 3 miles distant on a
calm night;
•
The development will contribute to flotsam which is washed up on local beaches;
•
The occupier of Kilbrandon House, Seil demands a report on the sound and visual
impact on the property.
Comments: Given the location of the site within a designated Area of Panoramic Quality
which accords the value of the landscape/seascape regional status, it is necessary to
give consideration as to the visual and landscape effects of the development relative to
the site to be removed from within the same designation, and the prospect of a mussel
farm being located within the application site in accordance with the Crown Estate lease
already held for such. This is addressed in Section C of Appendix A below. Site lighting
is confined to one navigation light on the proposed feed barge plus underwater lighting
for maturation purposes. The latter would not be visible at a distance nor at close
quarters from sea level, as such underwater lighting is generally only visible from
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elevated vantage points. Given the absence of transport routes or occupied buildings
along the adjacent coastline it will not present an issue at this site, as locations
overlooking the site will not be frequented during the hours of darkness. The feed barge
proposed is a type in use by the applicants at other locations in Argyll. The modern type
of generator employed is contained within the concrete structure of the barge and from
experience at those locations is not audible other than at close quarters.
Notwithstanding the low background ambient noise levels which would be a feature of
still nights, the distance to sensitive receptors is such that noise nuisance would not
produce amenity issues of significance associated with the operation of this site.
Kilbrandon House is approximately 2km distant from the application site, which would
move approximately 0.9km further away from that property than the existing site.
Objections in relation to recreation and tourism interests
•
The development will adversely affect local tourism related employment which is
founded upon wildlife and the environmental and scenic qualities of the area. By
comparison fish farm related employment is negligible;
•
Scotland’s landscapes are already being devalued by wind turbines, power lines,
inappropriate forms of rural development, shellfish and fin fish farms so a lot more
common sense is required before such developments are allowed to go ahead;
•
This is an area of scenic beauty and an iconic passage for vessels transiting from
south to north. The presence of the fish farm will degrade the area as a location for
recreational sailing;
•
The development will damage an important sheltered dive site and wildlife tourism;
•
The proposal will restrict access to the beach at Port na Morachd used for picnics
and boat trips;
•
The area will loose its unspoilt qualities and its
swimming;
•
The Scottish Canoe Association objects on the grounds that the development will
impede navigation and contribute to pollution to the detriment of the recreational
resource and the tourism potential of this scenic location.
attraction for kayaking and
Comment: It is for Members to weigh the balance between the economic and
employment advantages of the development against any adverse consequence which
the presence of the development might have for established tourism related
employment. Although the development will have localised impacts, these would be
offset in part by the loss of existing adverse effects as a consequence of the removal of
the existing site. There is no definitive research which leads to the conclusion that the
presence of fish farms in Scottish waters has thus far proven to be an acknowledged
deterrent to tourism, although given the importance of scenery as a tourism resource in
Argyll & Bute it is to be expected that inappropriately located sites may deter visits by
persons sensitive to the presence of such activities. SNH have not objected on the
grounds that the development would be prejudicial to the landscape and associated
recreational qualities of the area.
Objections in respect of navigation interests
•
The development poses an unwelcome impediment to navigation given that Seil
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Sound is already a difficult passage constrained by numerous hazards and a strong
tide.
•
Sailing to windward through the channel is challenging and the site will make this
impossible in some circumstances other than under power. Not all boats have
engines and to use them unnecessarily is wasteful.
•
An unmarked rock at the entrance to the sound causes yachts to give it a wide
berth.
•
The buoyed area will be so large that it will effectively halve the width of the
entrance to the Sound making navigation difficult for the less experienced.
Comment: Issues relating to navigation would be considered by Marine Scotland as
part of the Marine Licence required for the deployment of equipment in the water. As
this is a separate regulatory regime, technical matters relating to navigation are not
material planning considerations as such, although to the extent that they might have
consequences for the tourism and recreational potential of the area they have an
indirect bearing on the acceptability of the development. Whilst the seabed area of the
application site is extensive (in order to contain the limits of the mooring arrangements)
the surface equipment and the buoys around that equipment present much less of an
obstruction to navigation, particularly as the Northern Lighthouse Board do not require
the outer anchor points to be marked by buoys. There is a requirement for workboats
and larger well-boats to be able to access the site for servicing purposes. Although
there is some narrowing of the sound as a result of the equipment, the width of the
channel is still at least 420 metres at its narrowest point. It should be borne in mind that
any north-south transiting boat traffic would have to negotiate the much narrower Cuan
Sound between Seil and the Isle of Luing.
Objections is relation to the principle of marine salmon farming
•
The farming of fish in cages is a form of ‘battery farming’ which is environmentally
irresponsible and unethical in terms of animal welfare, and which devalues the
scenic landscapes within which it is situated;
•
Fish farm pose highly destructive effects upon both their immediate and wider
environments;
•
They are not a solution to over-fishing as small fish are taken to produce food for
farmed fish and the fish produced are not fit for human consumption due to
contamination with chemicals;
•
Underwater organisms are part of a finely balanced ecosystem which are fatally
threatened by pollution associated with fish farming;
•
There is an urgent need for world-wide standards to control fish farm escapes in
the interests of maintaining wild fish stocks;
•
The economic benefits of fish farming are overstated, particularly given the largely
foreign ownership of companies (in this case Polish). Shameless profiteering
should not be allowed to go ahead against the interests of the environment.
Comment: Consideration of the merits of this application requires to be confined to the
site specific circumstances of the case. Whilst there are those who regard marine fish
farming as being an unsustainable and environmentally harmful form of development as
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a matter of principle, it is a legitimate form of development supported by the Scottish
Government who have targets for the development of the industry as a growth sector in
the national economy and as valued source of employment within economically
deprived rural areas of the country.
Suggested matters to be addressed by conditions in the event permission is granted
•
Should permission be given, conditions should be imposed to require double
netting, no use of seal scarers, no shooting of seals, no increase in biomass, low
visibility equipment, a requirement to keep the site ‘clean’, and controls over
lighting.
Comment: Whilst control over deployment of ADD’s, appearance of equipment and
lighting are capable of being controlled by way of planning condition, matters controlled
by other bodies such as biomass (SEPA) and seal shooting (Scottish Government) are
not matters which could be the subject of competent planning conditions.
NOTE: Committee Members, the applicant, agent and any other interested party should note
that the consultation responses and letters of representation referred to in this report, have
been summarised and that the full consultation response or letter of representations are
available on request. It should also be noted that the associated drawings, application forms,
consultations, other correspondence and all letters of representations are available for viewing
on the Council web site at www.argyll-bute.gov.uk
(G)
SUPPORTING INFORMATION
Has the application been the subject of:
(H)
No – the development has
been the subject of a
negative EIA screening
opinion having regard to the
views of consultees and the
presence of the existing
farm which is to be removed
in the event that this
development proceeds
(i)
Environmental Statement:
(ii)
An appropriate assessment under the
Conservation (Natural Habitats) Regulations Yes – this form Appendix B
1994:
to this report.
(iii)
A design or design/access statement:
(iv)
–
Site
and
A report on the impact of the proposed Yes
development eg. Retail impact, transport Hydrographic Report, and
impact, noise impact, flood risk, drainage Chemotherpeutant
Modelling for bath and inimpact etc:
feed treatments.
PLANNING OBLIGATIONS
Is a Section 75 agreement required: No
No
Page 78
(I)
Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or
32: No
(J)
Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application
(i) List of all Development Plan Policy considerations taken into account in
assessment of the application.
‘Argyll and Bute Structure Plan’ 2002
STRAT DC 5 – Development in Sensitive Countryside
STRAT DC 7 – Nature Conservation and Development Control
STRAT DC 8 – Landscape and Development Control
‘Argyll and Bute Local Plan’ 2009
LP ENV 1 – Impact on the General Environment
LP ENV 2 – Impact on Biodiversity
LP ENV 6 – Impact on Habitats and Species
LP ENV 10 – Impact on Areas of Panoramic Quality (APQs)
LP ENV 12 – Water Quality and Environment
LP ENV 19 – Development setting, layout and design
LP CST 2 – Coastal Development on the Undeveloped Coast
LP AQUA 1 – Shell Fish and Fin Fish Farming
Expresses general support for fish farming subject to there being no significant adverse
effect on a range of specified considerations; those relevant in this instance being:
1.
2.
4.
5.
6.
8.
9.
11.
12.
Communities, settlements and their settings;
Landscape character, scenic quality and visual amenity;
National Scenic Areas and Areas of Panoramic Quality;
Statutorily protected nature conservation sites, habitats or species, including
priority species and important seabird colonies along with wild fish populations;
Navigational interests
Sites of historic or archaeological interest and their settings
Recreational interests
Existing aquaculture sites
Water quality
In the case of marine fish farming this support is further conditional on the proposals
Page 79
being consistent with the other policies of the Development Plan and Scottish Executive
Strategic Framework Guidelines.
Appendix A – Sustainable Siting and Design Principles
(ii)
List of all other material planning considerations taken into account in the
assessment of the application, having due regard to Annex A of Circular 4/2009.
Scottish Planning Policy (2010)
Circular 6/1995 ‘European Protected Species, Development Sites and the Planning
System’ and revised Scottish Government Guidance June 2000
Circular 1/2007 ‘Planning Controls for Marine Fish Farming’
Scottish Executive – ‘Locational Guidelines for the Authorisation of Marine Fish Farms
in Scottish Waters’ (2003 and updated June 2009 and December 2012)
‘A Fresh Start – the Renewed Strategic Framework for Scottish Aquaculture’ (2009)
‘Guidance on Landscape/Seascape Capacity for Aquaculture’ (SNH 2008)
‘Siting & Design of Marine Aquaculture Developments in the Landscape’ (SNH 2011)
‘Argyll & Firth Of Clyde Landscape Character Assessment’ (SNH 1996)
‘Argyll & Bute Local Biodiversity Action Plan’ Argyll & Bute Council
(K)
Is the proposal a Schedule 2 Development not requiring an Environmental Impact
Assessment: Yes
(L)
Has the application been the subject of statutory pre-application consultation
(PAC): No
(M)
Has a sustainability check list been submitted: No
(N)
Does the Council have an interest in the site: No
(O)
Requirement for a hearing (PAN41 or other): Yes - it is recommended that a predetermination hearing be convened in response to the number of representations
received from third parties and the complexity of the issues raised.
(P)
Assessment and summary of determining issues and material considerations
The proposal seeks permission for the installation of a marine finfish development of 12
No. 100m circumference (32m diameter) cages and a feed/service barge to be utilised
for the production of farmed salmon.
Page 80
The application site is located to the eastern side of Seil Sound close inshore to the
coast of the Degnish peninsula which also forms the north coast of Loch Melfort. It is
situated to the east of the small island of Torsa which lies to the east of Cuan Sound off
the north-east coast of the Isle of Luing.
The site lies off an area of remote, largely inaccessible and uninhabited land, where it
would be most readily experienced from boat traffic negotiating the Sound, or at a
distance from coastal properties south of Balvicar on the Isle of Seil. The site currently
benefits from a Crown Estate shellfish lease for mussel rafts, although it is not equipped
for production. The nearest fin fish site is operated by the applicants some 900m to the
north at Ardmaddy. This comprises a block of steel cages which it is proposed to
remove should this enlarged and more modern facility be consented. The proposal
therefore constitutes a relocation which also involves an increase in licenced peak
biomass from 1,300 to 2,500 tonnes. There are no other finfish farms in Seil Sound, the
nearest sites being well removed within Loch Melfort and around the coast of Shuna to
the south.
The proposal when submitted in 2011 prompted significant public objection in relation to
the anticipated pollution effects of the development and the associated consequences
for marine habitats and species. Pollution control in respect of marine fish farm
developments is exercised by the Scottish Environment Protection Agency (SEPA)
through the Controlled Activities Regulations (CAR licence) rather than by the Council.
Planning Authorities are cautioned in government advice against attempting to duplicate
other regulatory regimes, so other than pollution consequences for wild fish (which are
not subject to SEPA control), the remaining pollution effects of this development are not
material considerations for the planning application process. Likewise it is SEPA who
consent permitted biomass to be held at the site and not the Council. With this situation
in mind, the applicants agreed to the suggestion from officers that in this particular case
it would be appropriate for this planning application to be held in abeyance pending the
submission and determination of a CAR licence application by SEPA, so that issues
surrounding pollution could be addressed in the first instance, without leading to
inappropriate demand from third parties for these to be addressed as part of the
determination of this planning application.
In the event, a CAR licence application was pursued, and despite third party opposition
prompting consideration of the matter by Scottish Ministers, no intervention on their part
took place and SEPA proceeded to issue a CAR licence in respect of this 2,500 tonne
site towards the end of 2012. Subsequent to that, the determination of the planning
application is now being pursued.
The site lies outwith but adjacent to the Firth of Lorn Special Area of Conservation
(SAC), the closest point of which lies at Cuan Sound which is 1.8km away. Where a
development proposal is not connected with the management of a Natura site for nature
conservation, is likely to have a significant effect on the site (either alone or in
combination with other plans or projects), or effects are unknown, then the ‘competent
authority’ assessing the merits of a development proposal (in this case the Planning
Authority) is required to carry out an ‘appropriate assessment’ in order to evaluate
anticipated effects on the conservation objectives of the designated site. This applies
equally to developments located outwith designations which have the potential to impact
upon qualifying interests within the designations, as it does to those developments
proposed within designated areas. In such circumstances, only when it is concluded
‘beyond reasonable scientific doubt’ that the development under consideration will not
adversely affect the integrity of the designation, may permission be granted. In all other
circumstances permission must be refused (other than in the specifically excepted
cases where no alternatives exist, or there are imperative reasons of overriding public
interest for development to proceed).
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SEPA as ‘competent authority’ in respect of the CAR licence process conducted their
own ‘appropriate assessment’ prior to the granting of the licence for this site, which
concluded that the proposal would not compromise the nearby SAC designation.
Although SEPA’s assessment is a matter of record, as the planning process
commenced prior to SEPA’s consideration of the matter, it remains incumbent upon the
Planning Authority to conduct its own ‘appropriate assessment’ as part of the planning
application determination process. This can be found at Appendix B to this report. It
draws on SEPA’s conclusions (which are annexed to the appendix) as well as advice
provided by Scottish Natural Heritage. This concludes that impacts from solids flux, sea
lice treatments and nutrients are calculable, and having regard to modelling results and
accepted environmental standards, the development proposed will not adversely affect
the integrity of the SAC in light of its conservation objectives.
Neither SNH, SEPA, Marine Scotland, nor the District Salmon Fishery Board have
raised objections to the proposal. Objections have however been lodged by the Clyde
Fishermen’s Association, the Scottish Wildlife Trust, and adjacent Community Council’s
Scottish Planning Policy indicates the national importance of aquaculture in the context
of rural areas and that fish farming should be supported in appropriate locations, subject
to environmental considerations being assessed. Carrying capacity, landscape, natural
environment, historic environment and potential for conflict with other marine users,
including fishing and recreational interests, and economic factors will be material
considerations in assessing acceptability. Planning Authorities are cautioned not to
duplicate controls exercised by SEPA and Marine Scotland in their assessment of
proposals.
Government policy is to support the expansion of marine fish farming where it can take
place in environmental sustainable locations, where it does not exceed the carrying
capacity of the water body within which it is to be located and where it does not give rise
to significant adverse effects upon nature conservation, wild fish, historic environment or
other commercial or recreational water users.
The intention of this proposal is to
enable the replacement of a first generation fish farm with more modern equipment in a
more hydrographically favourable location, whilst also taking the opportunity to expand
capacity. Despite the increase in biomass, the surface area of the cages would reduce
marginally, although the less compact layout of circular rather than square cages would
lead to an overall increase in the extent of surface footprint.
It has already been demonstrated to SEPA’s satisfaction that the development can
operate without compromising recognised water quality standards and that discharges
from the site will not affect the integrity of nearby European protected habitats. The
location of the site between the largely unpopulated coasts of Degnish and Torsa are
such that it will not exert influence over the land to any degree beyond that already
associated with the nearby site which it is intended to replace. Both sites lie within the
same local plan designated Area of Panoramic Quality. Sensitive receptors on land on
the Seil coast to the north would benefit from the intended relocation of the site
southwards at increased separation. The site would however be relocated to a narrower
section of the Sound, which would bring those navigating the Sound closer to the
equipment. However the proposal would reduce the number of consented aquaculture
sites from one shellfish and one finfish site to the single site proposed, so any increased
visual impact would be offset by this reduction in the number of sites. Whilst the width of
the navigational channel will be reduced, at 420m this would not be to the extent that it
would frustrate navigation. This aspect would be addressed separately by the Marine
Licence process.
Significant representation against the proposal has been received, primarily on grounds
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that the development would increase pollution and pose a threat to protected habitats
and species. The extent and complexity of the issues raised are such as to warrant a
local hearing prior to the determination of the application.
(Q)
Is the proposal consistent with the Development Plan: Yes
(R)
Reasons why Planning Permission or Planning Permission in Principle Should be
Granted:
The proposal involves the establishment of a new marine finfish farm, which would
entail the de-equipping of an established farm to the north of the site and the
relinquishment of the lease, and which would supersede an undeveloped but consented
shellfish farm within the application site. It would maintain the number of finfish farms in
Seil Sound at a single site. Whilst the development would occupy a narrower section of
the Sound and would occupy a larger overall footprint, other than for the addition of a
feed barge, the aggregate surface equipment area would remain similar to that at the
existing site. The landscape and visual consequences of the development relative to the
existing position are considered acceptable, whilst the separation from sensitive
receptors avoids unacceptable amenity conflicts. Navigation of the Sound will remain
unimpeded and recreational interests will not be seriously prejudiced. The pollution
consequences of the development in combination with other fish farm developments
upon the protected habitats of the Firth of Lorn SAC have been assessed by means of
‘appropriate assessment’ and it has been determined that this proposal will not
adversely affect the integrity of this European marine designation. The proposal satisfies
the provisions of the development plan and there are no other material considerations,
including matters raised by consultees and third parties, which would outweigh the
presumption in favour of development established by the plan.
(S)
Reasoned justification for a departure to the provisions of the Development Plan
Not applicable
(T)
Need for notification to Scottish Ministers or Historic Scotland: No
Author of Report:
Richard Kerr
Angus Gilmour
Head of Planning and Regulatory Services
Date:
29th February 2013
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CONDITIONS AND REASONS RELATIVE TO APPLICATION 12/00904//MFF
1.
The development hereby permitted shall not be carried out other than wholly in
accordance with the following plans and details unless previously approved in writing
by the Planning Authority:
•
•
•
•
•
•
•
•
•
•
Application Form dated 13.06.11;
Plan 1 of 9 – current and proposed site locations and layout;
Plan 2 of 9 – location plan 1:10,000;
Plan 3 of 9 – location plan 1:25,000;
Plan 4 of 9 – Admiralty chart indicating mooring containment area;
Plan 5 of 9 – site layout plan;
Plan 6 of 9 – cage sections;
Plan 7 of 9 – net specifications;
Plan 8 of 9 – feed barge specifications (amended 18.12.12);
Plan 9 of 9 – feed barge appearance (amended 18.12.12).
Reason: For the purpose of clarity, to ensure that the development is implemented in
accordance with the approved details.
2. The stocking of the farm hereby approved with fish shall not take place until the fish pens
walkways, associated structures and moorings have been removed from the existing site
at Ardmaddy North (0.9km north of the consented site) and evidence has been
presented to the Planning Authority that the existing Crown Estate lease has been
relinquished in order to prevent subsequent re-equipping of that site.
Reason: Consent for this development is granted solely on the basis that this development
will replace the existing operation. Occupation of this site in association with the existing
site would produce unacceptable cumulative impacts as a result of the presence and
operation of multiple sites in inappropriately close proximity which would exceed the
carrying capacity of the receiving environment.
3. 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.
4. In the event of equipment falling into disrepair or becoming damaged, adrift, stranded,
abandoned or sunk in such a manner as to cause an obstruction or danger to navigation,
the developer shall carry out or make suitable arrangements for the carrying out of all
measures necessary for lighting, buoying, raising, repairing, moving or destroying, as
appropriate, the whole or any part of the equipment.
Reason: In the interest of visual amenity.
5. All lighting above the water surface and not required for safe navigation purposes should
be directed downwards by shielding and be extinguished when not required for the
purpose for which it is installed on the site.
Reason: In the interest of visual amenity.
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6. The finished surfaces of all equipment above the water surface including the feed barge
and surface floats and buoys associated with the development hereby permitted
(excluding those required to comply with navigational requirements) shall be nonreflective and finished in a dark recessive colour in accordance with colour schemes to
be agreed in advance in writing by the Planning Authority (by way of BS numbers or
manufacturer’s specifications) unless otherwise agreed in advance in writing by the
Planning Authority.
Reason: In the interest of visual amenity.
7. No deployment of Acoustic Deterrent Devices shall be permitted at the site unless the
model intended for use and the means of its use have been submitted to and approved
in writing by the Planning Authority, following consultation with Scottish Natural Heritage.
Thereafter deployment shall only take place in accordance with the duly approved
details unless any subsequent variation thereof is agreed in writing by the Planning
Authority.
Reason: In the interests of nature conservation.
NOTES TO APPLICANT
•
This permission shall only last for a period of three years from the date of this decision
notice unless the development is started within that period.
•
In order to comply with Sections 27A(1) of the Town and Country Planning (Scotland)
Act 1997, prior to works commencing on site it is the responsibility of the developer to
complete and submit the attached ‘Notice of Initiation of Development’ to the Planning
Authority specifying the date on which the development will start. Failure to comply with
this requirement constitutes a breach of planning control under Section 123(1) of the
Act.
•
In order to comply with Section 27B(1) of the Town and Country Planning (Scotland)
Act 1997 it is the responsibility of the developer to submit the attached ‘Notice of
Completion’ to the Planning Authority.
•
In terms of condition 1 above, the council can approve minor variations to the approved
plans in terms of Section 64 of the Town and Country Planning (Scotland) Act 1997
although no variations should be undertaken without obtaining the prior written
approval of the Planning Authority. If you wish to seek any minor variation of the
application, an application for a non material amendment (NMA) should be made in
writing to Planning Services, Whitegates Office, Whitegates Road Lochgilphead, PA31
8SY which should list all the proposed changes, enclosing a copy of a plan(s) detailing
these changes together with a copy of the original approved plans. Any amendments
deemed by the Council to be material, would require the submission of a further
application for planning permission.
•
The applicant should have regard to the navigational marking requirements of the
Northern Lighthouse Board as set out in their consultation response.
•
The deployment of Acoustic Deterrent Devices at this site may be subject to a
requirement for a licence to be obtained in advance from Scottish Natural Heritage in
respect of disturbance to cetaceans, in addition to the requirements of condition 7
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above. Early consultation with SNH over the matter of the prospective deployment of
ADD’s is recommended.
APPENDIX A – RELATIVE TO APPLICATION NUMBER: 09/00905/MFF
PLANNING LAND USE AND POLICY ASSESSMENT
A. Location, Nature and Design of Proposed Development
The applicant in this case is Lakeland Marine Farms Ltd (part of the Meridian Group)
who currently operate a number of finfish farming sites across Argyll including an
existing site at Ardmaddy (referred to as Ardmaddy North for the purposes of this
application). That site is a first generation farm comprising 18 No. 10m deep 24m x
24m square metal cages, projecting 1.4m above the surface, with bird exclusion nets
and several sheds mounted on the walkway structures, but without a feed barge. It
provides an aggregate cage surface area of 10,368m2 within an overall occupied
surface area of 13,440m2, secured within a seabed a mooring area of 145,000m2. It
has a licenced maximum biomass of 1,300 tonnes. The applicants seek to replace that
equipment whilst at the same time expanding the productive capacity of the farm, and
in so doing have identified a hydrographically more favourable site 900m to the south,
which would lend itself to the increased biomass proposed.
The proposed site (referred to as Ardmaddy South for the purposes of this application)
lies on the same side of the Sound some 900m to the south of the location of the
current equipment. The site is located off the west coast of the Deignish peninsula at
Port na Morachd, about 1km to the north of Deignish Point and on the opposite side of
the Sound to the small island of Torsa. The proposal is to equip the site with 12 No.
100m circumference circular cages grouped together in a 6 x 2 rectangular mooring
grid, producing a slightly reduced aggregate area occupied by surface equipment that
at Ardmaddy North at 9,549m2, within a larger 179,800m2 mooring area (580m x
310m). The cages would be fitted with a centrally supported top net structure giving an
overall maximum height of 2.6m at the cage centre point. The site would have a
maximum biomass of 2,500 tonnes - 1,200 tonnes greater than the existing site at
Ardmaddy North. The main difference in the appearance of the site will be accounted
for by its less compact format due to the bigger gaps between circular cages, and the
addition of a feed barge at the north end of the cage group. It will therefore occupy a
larger area of water (cage grid within a buoyed support structure of 100m x 300m),
despite the fact that the surface area of the equipment within this overall area will be
less than that of the pens at the present site.
The application site already benefits from a Crown Estate lease for a shellfish farm
comprising 6 No. 10m2 mussel rafts within a 55,000m2 mooring area, although the site
is not currently equipped for production. It is intended that the proposal will supersede
the shellfish site and that the lease for the Ardmaddy North site would be relinquished
and the equipment removed, in the event that this larger replacement farm at
Ardmaddy South is consented.
The proposed cages comprise circular polyethelyene flotation rings approx.1.2m high
above the waterline with a diameter of 32m, from which 15m deep nets will be
suspended. The cages will be fitted with a ‘hamster wheel’ top net support 2.6m high
which will enable the fitting of 25mm mesh nets over the cages for the purpose of
excluding pisciverous birds. The nets are fitted with false bottoms (seal blinds) to deter
predator attacks from below, and are held in tension, again to resist predation. The
cages will be secured in place by a rectangular 100m x 300m mooring grid with
mooring lines and rock anchors used to secure the position of the grid relative to the
seabed. The site will be aligned SW - NE parallel to, and close inshore to, the mainland
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coast. The feed barge originally proposed was 18m x 26m in area although this has
since been reduced by way of amended plans showing a much smaller barge 14.0m x
10.5m in area and 5.3m in height maximum, dependent upon the quantity of feed held.
The barge comprises four silos, a generator, maintenance and crew accommodation. It
will be finished in a recessive colour with generator noise only audible at close
quarters. The site will be staffed by 3 to 4 full-time employees plus 2 part-time staff and
will safeguard the jobs currently associated with Ardmaddy North. Deliveries to the site
will be by sea from Lakeland’s existing shore base at Loch Craignish. Personnel
transfers will take place by boat from a staff facility at Croabh Haven. Underwater
lighting would be used to control maturation and maximise growth December to May
every second year with 2 No, 1,000w lights being used 5m beneath each cage. These
would be powered by the feed barge generator and would produce a surface glow only
visible at close quarters or from elevated vantage points. Other lighting on the site, with
the exception of navigational requirements, would be restricted to essential
requirements so as to avoid unnecessary illumination on the site.
The section of the Sound to which the site is to be relocated is narrower than that
occupied by the equipment at Ardmaddy north being some 700m wide at this point and
narrowing off to the south due to the presence of the island of Torsa. The nearest fish
farm site is that at Ardmaddy North (to be relinquished) with the next nearest sites
either being within Loch Melfort or off the north coast of the island of Shuna, some 5km
to the south. Seil Sound is ‘unclassified water’ for the purpose of Marine Scotland’s
Locational Guidelines for fish farms in marine waters, as it is a complex open water
body which does not suit the modelling used to inform the guidelines (which relate
more to sealochs which are most susceptible to cumulative impacts). In view of this the
applicant has undertaken nutrient enrichment modelling which has been accepted by
Marine Scotland and by SEPA in their ‘appropriate assessment, which in turn informs
the conclusions of the Councils own assessment.
The site lies within Management Area 16d (Seil Sound to Loch Craignish). There is no
Area Management Agreement in place for this location at the moment due to the
decision of wild fish interests to withdraw from the former Lower Lorn AMA. The
applicants are, however, part of the Lower Lorn Farm Management Agreeement with
Kames Fish Farm which ensures synchronous stocking and treatments between the
two companies actively farming in this area. The intended peak biomass (fish tonnage)
for the overall site is 2,500 tonnes. The stocking density would be 17.4kg per m3 max.
The production cycle of the farm would be 22 months with 2 months left fallow to assist
in benthic (sea bed) recovery.
The site would be operated in compliance with the Scottish Salmon Producers
Organisation’s ‘Code of Good Practice Guidelines for Scottish Finfish Aquaculture’.
This sets out more than 300 main specific compliance points which cover all aspects of
finfish good practice including:
•
•
•
•
Fish Health – good husbandry and harvesting operations;
Protecting the environment – including sea lice management and containment
standards;
Welfare and husbandry – breeding and stocking density;
Detailed annexes giving further technical guidance on good practice, including
the National Lice Treatment Strategy, Integrated Sea Lice Management,
Containment, and a Veterinary Health Plan.
The applicants have provided details of their Emergency Mortality Removal and
Escapes Contingency procedures, manufacturers’ site specific attestations for
equipment, nets and moorings, their Veterinary Health and Biosecurity Plan and their
Predator Risk Assessment and Predator Control Plan. With regard to predator control,
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it is noted that the ES states that Acoustic Deterrent Devices (ADDs) would only be
deployed in circumstances where the site becomes subject to attempted predation. As
a last resort in the event of persistent rogue seal activity, the shooting of seals may
take place in accordance with a Scottish Government licence already held by the
company.
B. Natural Environment - Fresh Water, Marine Environment and Biodiversity.
The provisions of Policies STRAT DC 7, LP ENV 2 and LP ENV 6 all seek to resist
development which is considered likely to result in a significant adverse impact upon
internationally, nationally or locally important habitats and/or species.
The application site is not located within any European or national nature conservation
designations. Whist the proposal lies outwith the Firth of Lorn Special Area of
Conservation (SAC) it is within potential influencing distance of the SAC, the nearest
point of which is some 2km away at Cuan Sound, and for that reason a Habitats
Regulations ‘appropriate assessment’ has been carried out in respect of qualifying
interests of this European marine site. The Sound is also frequented by species of
nature conservation interest including seals and wild salmonids, for which development
of the type proposed could have consequences in terms of displacement or deterrence.
Salmon and Sea Trout are vulnerable to interaction with farmed fish and both a UK
BAP and the A&B LBAP species and included in the Argyll & Bute Local Biodiversity
Action Plan. The Sound also host to white cluster anemone, which is a Priority Marine
Feature.
Seabed (Benthic) Impacts:
The development will affect seabed conditions as a consequence of the deposition of
organic matter in the form of faeces. Furthermore, although the industry has made
advances in the reduction of waste food as a result of more sophisticated feeding
regimes, waste food also contributes to seabed deposition. This can take the form of
localised smothering of the seabed as well as more distant deposition arising from the
propagation of waste matter from the site. The quantity and the extent of deposition are
influenced by the tonnage of fish held, hydrographic and bathymetric conditions.
Seabed impacts are regulated separately by SEPA via the CAR licence process, which
determines maximum biomass with regard to the carrying capacity of the particular site.
The applicants have provided a benthic survey, a visual assessment and a modelling
assessment in support of their proposal, all of which have been considered by SEPA
as part of their CAR licence application and which have helped inform SEPA’s
conclusions in respect of their ‘appropriate assessment’. The seabed below the
proposed site comprises firm mud, shell and gravel which supports a diverse range of
mollusc, crustacean and echinoderm. There are no specifically designated habitats
below or in the immediate vicinity of the site. Modelling has been used to predict a site
specific Allowable Zone of Effect (AZE) in order to demonstrate compliance with
SEPA’s requirements. This indicates that there will be localised enrichment with high
dispersal at what is regarded to be a moderately flushed site. SEPA has accepted this
conclusion along with the fact that there will be low cumulative impact as the next
nearest site is 2.5km distant. The CAR licence which was issued at the end of 2012
addresses the discharge consequences of the development in terms of smothering as
well as chemical treatments and cumulative nutrient enrichment.
SNH and SEPA are both content with the benthic surveys undertaken by the applicant
and neither have objections to the proposal on the grounds of unacceptable benthic
impacts.
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Water Quality Impacts:
Enrichment of water by nutrients released from salmon farms can cause an
accelerated growth of algae and higher forms of plant life to produce an undesirable
disturbance to the balance of organisms and the quality of water.
This site is located at the SE entrance to Seil Sound which is subject to tidal currents
producing a moderately flushed site, and modelling indicates that waste dispersal will
be into the deeper water of the Sound as well as to Loch Melfort and Shuna Sound.
Estimated nutrient enrichment is well below the threshold of 50% above the OSPAR
and UTAG reference levels, and consented sea lice treatments have been set in the
CAR licence for the site at a level which will not breach SEPA’s Environmental Quality
Standards. Whilst localised impacts are anticipated from particulate and dissolved
wastes, modelling results indicate that these, when considered cumulatively with other
consented sites, will not result in a significant deterioration in the quality of the
receiving water body; a position accepted by SEPA in the issuing of a CAR licence for
the biomass sought by the applicants.
Neither Marine Scotland Science nor SEPA have raised objection to the proposal in
respect of the predicted impact of the development upon water quality.
Interaction with Predators:
Salmon farm predators are generally piscivorous birds and seals, with the latter tending
to be the most frequently encountered predators on marine farms in Scotland. The
presence of sea cages may attract higher concentrations of predators to the locality of
the site, although good husbandry and hygiene procedures will help to reduce the
attraction of predators. Tensioned netting on fish cages prevents and deters both seals
and diving bird attacks, although regular removal of mortalities from the bottom of the
nets and regular maintenance of the nets to maintain their integrity is necessary to
avoid attempts at predation. Top nets are to be installed on the cages to avoid
predation by birds from above the waterline. Bird nets require to be maintained to a
high standard and properly tensioned eliminate the opportunity for birds to become
entangled or to be able to enter the cage. The fish cages themselves are to be
manufactured to current industry standards, with a net specification, tensioning
arrangements, false bottoms and an installation, inspection and maintenance regime to
meet the SSPO ‘Code of Good Practice’ requirements. It is clearly in the operator’s
interest to ensure that equipment is specified and maintained in a manner to ensure
containment of the farmed fish. Site specific equipment attestations have been supplied
to confirm that, in the respective manufacturer’s opinions, the equipment intended for
use on this site is suitable and sufficiently durable to be deployed having regard to the
characteristics of in the particular marine environment proposed.
The ES does not identify any major colonies of predators in the vicinity of the
application site, although there are recorded haul outs within 2km at Cuan Sound and
Scoul Eilean. The Environmental Statement concludes that proposed use of good
husbandry (mortality and moribund fish removal) and hygiene practices based on
experience at other sites, coupled with the use of tensioned nets and top nets will be
sufficient to deter predators at the proposed site. In the event of persistent predator
activity, the applicants wish to maintain that option to deploy Acoustic Deterrent
Devices (ADD’s) to scare away seals in order to avoid to resorting to the shooting of
seals. Technology has improved in recent years with devices available which are more
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effective than previous systems and are more localised and targeted in their impact.
SNH have asked that deployment of ADD’s be subject to their approval via planning
condition. Only in extreme circumstances would resort be made to the shooting of
seals under government licence. The applicants already hold a Seal Management
Licence for their 9 sites on the west coast, including Ardmaddy North, to which they
would request this proposed site by way of an addition in the event that planning
permission is granted. During 2012 one seal was shot in connection with the
applicant’s farm at Ardmaddy North.
Scottish Natural Heritage has not raised objection to the proposal on the grounds of
unacceptable consequences for potential predators or impacts on non-target wildlife.
Interaction with Wild Salmonids:
Farming of salmon in the marine environment can give rise to well-known
consequences for wild fish as a result of disease transmission, sea lice propagation
and escapes which can lead to competition and inter-breeding, with consequences for
the genetic dilution of native wild stocks. The potential for escapes (as with predator
control) can be reduced by having an equipment specification determined by site
specific wave and climate analysis so as to ensure that it is fit for purpose. An
associated inspection and maintenance regime is then required to ensure on-going
containment integrity. Predator control plans, and escapes contingency plans, as
submitted by the applicant, are also important elements in risk management.
Although containment risks can be managed, they cannot however be eradicated and
there remains a residual risk that an unforeseen event can propagate escaped farmed
fish in large numbers into the uncontrolled marine environment. Escapes of farmed
stock are generally low, but can occur through equipment failure, predation, operator
error, severe weather or foul play. By adherence to the SSPO ‘Code of Good Practice
Guidelines’ the applicant seeks to minimise this residual risk as far as is practicable.
Likewise, via good husbandry practices, regular inspection and the administration of
medicines in accordance with veterinary health plans, outbreaks of disease which
could have consequences for wild fish can be managed.
The most intractable issue influencing the interaction between farmed salmon and wild
fish species is that of sea lice transmission. Farmed fish are routinely hosts to parasitic
sea lice, the numbers of which require to be controlled in order to assure the health of
farmed fish and to avoid lice propagation into surrounding waters. Wild salmon can be
exposed to sea lice from fish farms close to salmon rivers during their migration
periods, whilst sea trout tend to remain in coastal waters throughout the year, so are
potentially at greater risk. In this case there are no major wild salmon fisheries within
15km of the site.
The applicant proposes to control sea lice in accordance with current industry practice,
via the use of in-feed treatments and well-boat administered bath treatments, whilst
adopting good management practices such as single year stocking and synchronous
stocking, fallowing and lice treatment with other sites within the Lower Lorn Farm
Management Agreement. All sea lice bath treatments are intended to be carried out on
board well-boats (rather than the more traditional method of net shallowing) which is a
superior method, in terms of control over exposure time and dosage to ensure the
effectiveness of those treatments. It also enables more than 50% reduction in the use
of chemotherapeutants over treatment administered within cages. The applicants are
also trialling the use of wrasse as a means of biological control over sea lice hosted on
farmed salmon, which again presents opportunity to reduce the administration of
chemical controls. .
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However effective the control measures are in practice, it is an inevitable consequence
of holding fish in such quantities that significant numbers of sea lice will be propagated
from the site. How these are dispersed will depend on local factors such as wind
direction and residual current. The distribution of farm derived lice in the marine
environment is not well understood although it is known that in favourable conditions
they can travel considerable distances from source.
In addition to sea lice propagation, failure of containment can lead to escapes which
pose a threat to wild fish due to competition or through breeding. The applicants
consider that their tensioned net systems are appropriately specified so as to be fit for
purpose at the site and that they are accompanied by appropriate management
measures and predator control arrangements to minimise the prospect of escape
events. None of the applicant’s fish farm sites in Argyll have to date been the subject of
mass escapes.
The conclusion of the applicant’s supporting information is that the site will not
prejudice wild fish interests. The applicants have stated that they have not had sea lice
problems with the existing site at Ardmaddy North and sea lice treatment already
consented by SEPA is suitable to allow efficacious treatment of lice populations at this
enlarged site in accordance with recognised standards.
Neither Marine Scotland nor SNH have objected to the proposal on the grounds of the
threat posed to wild salmonids. The District Salmon Fishery Board have not objected
subject to removal of the existing site, but have expressed their preference for the site
to operate on the basis of reduced biomass in order for effective treatment to be
demonstrated. Given the capital investment in an enlarged facility such as this, a
conditional obligation for under-stocking would not be a reasonable planning
requirement.
Impact upon Species and Habitats of Nature Conservation Importance:
No species or habitats of nature conservation importance were identified by the
applicant’s submitted seabed survey within the predicted depositional footprint of the
proposed farm. The presence of white cluster anemone (a Priority Marine Feature)
150m north of SPA’s Allowable Zone of Effect (AZE) has been pointed out by the
Scottish Wildlife Trust. This has been accounted for by SNH in their response to
SEPA’s CAR licence consultation, with the view being expressed that whilst localised
changes to the structure of the colony may occur as a result of the operation of the
farm, these are unlikely to affect the long-term viability of the species at this location or
its overall conservation status in the context of north Argyll.
There are no nature conservation designated sites (SSSI’s or SAC’s) in the immediate
vicinity of the proposed farm, although it does lie within a Marine Consultation Area
defined by Scottish Natural Heritage in view of the overall quality of the marine
environment. The closest designated site is the Firth of Lorn SAC to the west of Cuan
Sound and the Isle of Luing identified for its rocky reef habitat. The SAC covers open
water to the west of Seil and Luing and waters around Scarba and to the north of Jura,
but excludes the more enclosed waters of Seil Sound, Shuna Sound and Loch Melfort.
A map of the designated area appears in the ‘appropriate assessment’ at Appendix B.
Covering an area of approx. 210km2 the Firth of Lorn SAC has been designated for its
rocky reef habitats which support an exceptional marine biodiversity, with associated
communities and species which are amongst the most diverse in both the UK and
Europe. Conservation objectives for the SAC are to avoid deterioration in the qualifying
interest (rocky reefs) thereby ensuring that the integrity of the designation is
maintained. Although at a distance from the designated SAC, there may be potential
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for the proposed development to affect the designated area by means of the deposition
of organic waste and by chemotherapeutants transported into the designated area by
tidal currents. The proposed fish farm has the potential to affect qualifying interests in a
number of ways. Firstly, from smothering as a result of the transport and deposition of
solids; secondly, due to toxicity from the exported residues of chemical treatments; and
thirdly, from the cumulative impact of the development with other sites within
influencing distance of the SAC.
Where a development has the potential to give rise to significant effects upon the
qualifying interests of a European Natura designation, the ‘competent authority’
considering the merits of any development proposal within, or within influencing
distance of, the designated area is required to undertake ‘appropriate assessment’, if it
considers that it presents the possibility of significant environmental effects upon that
designation. Where a likely significant effect is anticipated, development may only
proceed if the ‘appropriate assessment’ concludes beyond ‘reasonable scientific doubt’
that the integrity of the SAC will not be compromised. In all other circumstances to
satisfy the requirements of the Habitats Directive, permission must be refused (other
than in the specifically excepted cases where no alternatives exist, or there are
imperative reasons of overriding public interest for development to proceed).
Interaction between the site and the SAC designation in terms of the transport of
organic waste and chemotherapeutants has been reviewed by SEPA by way of a
Habitats regulations ‘appropriate assessment’ in association with their CAR licence
process. An ‘appropriate assessment’ on behalf of the Planning Authority drawing
heavily upon the conclusions reached by SEPA, can be found at Appendix B to this
report. In reaching its own conclusions as set out in that appendix, the Council has
consulted both with SEPA and SNH for their views on the matter. Dispersal modelling
accepted by SEPA indicates that solids and in-feed chemical residues will be
predominantly exported via Cuan Sound into a dispersive environment where
additional amounts will not be such as to breach Environmental Quality Standards
(EQS) set by SEPA, or to compromise the conservation objectives of the SAC.
The Planning Authority’s ‘appropriate assessment’ has considered the likely
environmental effects upon habitats and species associated with the SAC and has
concluded that the proposal both in isolation, and in combination with other consented
sites, will not have an adverse effect on the integrity of the site, in the light of its
conservation objectives.
Scottish Natural Heritage has not raised objection to the planning application or the
SEPA CAR licence on the grounds of unacceptable consequences for marine
mammals, otters, the priority marine feature ‘white cluster anemone’ or the qualifying
reef habitat of the SAC
Conclusion
The proposal is considered consistent with Local Plan Policy LP AQUA 1 (5 and 12)
and other relevant development plan policies insofar as it would not significantly
prejudice water quality and associated biodiversity interests.
C. Landscape/Seascape Character
The application site lies inshore in a relatively remote location off the west facing coast
of the Degnish peninsula. From the land the site would be visible from the west facing
slopes above the coast, but there is no road access to this area, no overlooking
habitation and little public access appears taken to this area other than for the path
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between Loch Melfort and Ardmaddy which is set well back from the coastline behind
the high ground overlooking the site. The opposing coast is formed by the eastern side
of the small island of Torsa. There is no habitation on the east facing coast of the
island, and there are unlikely to be few sensitive receptors affected. The site would be
visible, but at a distance in excess of 2km, from a handful of isolated properties to the
north-west on the Isle of Seil, which can be found close to the coast and to the south of
Balvicar. There will be some limited visibility from the land either side of the Cuan Ferry
but remaining visibility from Luing would be from the largely unpopulated east coast,
other than for long distance visibility, end on to the site, from Toberonochy at over 5km
away. The existing site at Ardmaddy North lies closer to the closest properties south of
Balvicar than the location of the proposed site, which lies at an increased distance from
any habitation. Any disbenefit arising from the enlarged site, including the additional
impact of a feed barge would be largely offset by the removal of the existing equipment
closer to Seil. Both the existing fish farm at Ardmaddy North and the proposed site lie
adjacent to areas designated as ‘sensitive countryside’ and ‘Areas of Panoramic
Quality’ by the adopted local plan, so share the same development plan context.
The ‘Area of Panoramic Quality’ accords the locality a scenic designation of regional
status. The provisions of Policies STRAT DC 8 and LP ENV 10 seek to resist
development which is considered to have a significant adverse impact upon the key
landscape characteristics of these designations. Both the mainland and the islands
either side of Seil Sound are identified as falling within the ‘Craggy Coast and Islands’
landscape character type, identified by Scottish Natural Heritage as having a small
scale diverse topography within a distinct seascape context which provides a unifying
element. The more inaccessible sections of coast exhibit a sense of isolation and
naturalness which is less apparent on the more inhabited stretches of coast. The APQ
recognises the panoramic value of the seascape and the views to and from the islands.
The intended location lies close inshore and parallel to the coast, where it would benefit
from a dark coloured and elevated landscape backdrop, whilst the equipment is lowlying and to be finished in a recessive colour. This meets with SNH good practice
guidance on the location and design of marine aquaculture development. Most
terrestrial receptors (roads, transport routes, frequented public locations) would be at a
significant distance from the equipment which would not assume importance in its
landscape setting when appreciated from such locations. The lack of access being
routinely taken to the isolated stretch of coast on the mainland immediately above the
site is such that there will be few receptors taking closer quarter views down into the
equipment.
The primary effect upon the perception of the landscape/seascape of Seil Sound will be
in terms of those transiting the Sound by boat. Seil Sound is a body of enclosed water
which is frequented by recreational boat traffic and a recognised cruising route. Yachts,
tour boats and kayaks currently pass the existing site at Ardmaddy North, so their
experience of the Sound is already influenced by the presence of aquaculture
equipment. Although the proposed site is larger in extent and the Sound is narrower in
the vicinity of the proposed site, there will be a small reduction in the aggregate surface
area of the equipment and the round cages proposed are less visually intrusive that the
existing square cages, which form a more compromising block with less intervening
water. Whilst a feed barge is proposed, and this is an additional element not present at
Ardmaddy North, the applicants have reduced the scale of that proposed significantly in
order to limit the impact of this structure. Feed barges are now an almost standard
requirement in the servicing of modern marine fish farm operations and it would be
unrealistic to expect a site of this nature not to include one. Provided that the model
selected is finished in a recessive colour it will not be an unacceptable element of the
development.
Page 93
The proposal would also remove the prospect of the existing shellfish lease being
taken up for the siting of mussel rafts on the application site. The removal of the
equipment form Ardmaddy North in favour of the proposed development would mean
that there would still be one fish farm to be passed by boat traffic at the southern end of
the Sound. Despite the revised location and the altered appearance of the equipment,
there would be overall little change in the perception and the appreciation of
landscape/seascape from the water, with aquaculture retaining a presence in the
locality by way of a single finfish farm, well removed from the next closest aquaculture
site, so that cumulative impact does not become unacceptable in landscape or visual
terms.
Scottish Natural Heritage are of the opinion that the landscape and visual effects of the
development will be localised. Whilst it has been suggested that the impact of the feed
barge could be reduced by repositioning it to the southern end of the site, where it
would benefit from screening by the higher part of the island of Torsa, the applicants do
not consider this to be desirable operationally as their practice is to site barges on the
less exposed ends of sites, where in the event of storm damage, the threat to the
integrity of the cage group is less. The applicant’s response has been to downsize the
scale of the intended barge in its originally proposed location as an alternative means
of addressing this suggestion.
Conclusion
The proposal complies with Local Plan Policy LP AQUA 1 (2 and 4) and other relevant
development plan policies insofar as it would not significantly prejudice landscape
character, visual amenity or designated areas of scenic quality. In view of the absence
of other aquaculture in the immediate locality, and the intention to remove equipment
from the existing site at Ardmaddy North in the event that permission is granted, the
development does not present any cumulative impact issues of concern.
D. Other Marine Users
The development of the proposed site would entail the relinquishment of the existing
Crown Estate lease for the fish farm site at Ardmaddy North. This would release new
ground for inshore creel fishing once the seabed has had opportunity to recover from
the presence of an operational farm. The Sound is not used for trawling. Although the
Clyde Fishermen’s Association has objected to the development their objections tend
to be founded around the growth of the aquaculture sector in general and the perceived
unsustainability of the industry rather than upon specific shortcomings associated with
the location of the application site or the details of the proposal.
The proposed site is located in a narrower section of the Sound than the current site
and the proposed mooring area extends further out into the Sound than the area which
is the subject of the current Crown Estate shellfish lease area. Despite that, the
equipment is to be located close inshore to the east of existing navigational and RYA
cruising routes, which will ensure that the surface equipment and the associated
moorings do not impinge upon access into and out of the south of the Sound by boat.
Navigational implications of the development will be considered separately by Marine
Scotland under the marine licencing procedure. It should be borne in mind that whilst
the seabed foot print of the mooring area is extensive at 580m x 310m, around a third
of the seaward end of the mooring lines will be on the seabed rising up to the cage
mooring grid which is supported by riser buoys 8m out from the cages. Therefore
navigation relatively close to the cage group is possible, and indeed the installation has
been designed to afford sufficient draught for a large well boat to service the farm and
for workboats to come alongside the cages.
Page 94
Conclusion
The proposal complies with Local Plan Policy LP AQUA 1 (6 and 11) and other relevant
development plan policies insofar as it would not significantly prejudice navigation and
the continued exploitation of traditional fishing ground.
E. Noise
Noise associated with the development will arise from the operation of workboats and
other vessels associated with the fish farm, plus noise from the generator within the
concrete feed barge. Given the absence of local habitation or other sensitive receptors,
and the transient nature of other boat traffic, this will not present a problem in terms of
the operation of the site. The applicants already utilise the type of feed barge intended
to be employed at this site and experience of that in operation is such that it is evident
that generator noise will not pose a threat to amenity.
F.
Transport
As with the existing site at Ardmaddy North, there will be no need for access to the
locality of the site by road. Servicing and deliveries will be undertaken by boat from the
applicant’s existing shore base in Loch Craignish. Personnel will take access by small
boat from an existing facility adjoining the marina at Craobh Haven. Stocking and
harvesting of fish, and treatment of sea lice, will take place by larger vessels.
G. Conclusion
The proposal has given rise to considerable public objection. Concerns have been
expressed by 3rd parties in terms of pollution of the water environment, impact upon
habitats and species, and in view of the presence of the equipment in terms of
landscape character, navigating interests and the experience of those transiting the
Sound by boat. The extent of the issues raised regarding pollution and the extent of its
suggested consequences for nature conservation prompted the application being held
in abeyance for some considerable time, in order to afford the applicant opportunity to
address these matters and for them to be assessed in detail by SEPA. Given that
pollution issues are largely the remit of SEPA, and having regard to the government
position that Planning Authorities should not seek to duplicate other regulatory regimes,
it is inappropriate that those matters which are properly the responsibility of SEPA
should be revisited as part of this application.
Of those other matters which fall within the remit of the Planning Authority none have
been identified which point to the need to withhold planning consent. The proposal is,
in part, a relocation of an existing site, and also an enlargement of production capacity.
It enables the removal of first generation equipment and the use of more modern
techniques in a site which is better flushed and which presents opportunity to hold
increased biomass without breaching SEPA’s environmental quality standards. It would
maintain a single presence of aquaculture development at the southern end of the
Sound and would enable an increase in production capacity without seriously
prejudicing any of the considerations which are material to the determination of the
application. In those circumstances it can be considered to be compliant with Local
Plan Policy LP AQUA 1 and other relevant development plan policies, and there are no
Page 95
other material considerations identified of such magnitude as to warrant other than
planning permission being granted in conformity with development plan policy.
Page 96
APPENDIX 11/1066/MFF:
NAMES & ADDRESSES OF REPRESENTEES
OBJECTORS:
Miss Samantha Croll
Martin McNally
Mr William Todd
Mr Terence Hollis
Andrea Jack
Mr Stephen Jowett
Dr Douglas Wilcox
Mr Richard Bath
Mr Oliver Jay
Mr Stephen Milner
Mr Richard Wesley
C Jade
Mrs Susan Clarke
Rosanna Salter
Hugo Salter
Monica Patnain
0/1 11 Barrington Drive
Glasgow
G4 9DS
0/2 6 Roness Drive
Glasgow
G52 1HB
0/2 Flat
61 Fergus Drive
Glasgow
G20 6AH
1 Cairns Place
1 Cairns Place
Dollar
FK14 7LH
1 Cedar Grove
Cardross
Dumbartonshire
G84 5JW
1 Church Road
Altofts
Normanton
Wakefield
WF6 2NN
1 Colonsay Drive
Newton Mearns
Glasgow
G77 6TY
1 East Hermitage Place
Edinburgh
EH6 8AA
1 Felkington Farm Cottages
Berwick Upon Tweed
TD15 2NR
1 High Street
Eydon
Northamptonshire
NN11 3PP
1 Kilbrandon Cottages
Balvicar
Oban
PA34 4RA
1 Mahonia Drive
Langdon Halls
Basildon
Essex
SS16 6SD
1 Mc Calls Terrace
Oban
PA34 4JE
1 Rock Farm Cottage
Nettlestead
Maidstone
Kent
ME18 5HT
1 Rock Farm Cottages
Gibbs Hill
Nettlestead
Maidstone
Kent
ME18 5HT
1 Sophia Square
London
31/07/2011
O
12/09/2011
O
23/11/2011
O
18/07/2011
O
01/08/2011
O
18/07/2011
O
07/09/2011
O
18/07/2011
O
07/09/2011
O
20/07/2011
O
20/07/2011
O
05/08/2011
O
21/07/2011
O
22/08/2011
O
22/08/2011
O
03/08/2011
O
Page 97
Mr Keith Morris
Mrs Deborah Chopping
Mrs Rita Summers
Kay Griffin
Nathan And Nicola Brown
David Maseska
Kristen Maseska
Judy Murphy
Dr Anthony Beck
Mr Juan Rodriguez Dominguez
Dr Stella Pytharouli
Carole Thomas
Alex Dimopoulos
B A Laroult
J A Lamont
Morven Hughes
Mrs Dorothy Kisielewski
Mr And Mrs P Hires
SE16 5XL
1 West View
Church Road
Grange over Sands
LA11 7RB
10 Burywick
Harpenden
AL52AE
10 Napier Road
Monton
Eccles
Salford
M30 8AG
10 Roseworth Crescent
Newcastle
NE3 1NR
10 St Marys Close
Roughton
Norfolk
NR11 8QF
1000 Chestnut Drive
Longmount
Colorado
USA
80503
1000 Chestnut Drive
Longmount
Colorado
USA
80503
101 Flatford Place
Kidlington
Oxford
OX5 1TG
102 Potovens Lane
Wakefield
WF1 2LQ
105 Dewi Clos Saint
Cardiff
CF11 9EX
107 Rottenrow
Glasgow
G40NG
108 Eaton Road
Appleton
Abingdon
Oxon
OX13 5JJ
109 Cleveland Road
North Sheilds
Tyne And Weir
109 Cleveland Road
North Sheilds
Tyne And Weir
109 Cleveland Road
North Sheilds
Tyne And Weir
NW29 0PF
109 Cranbrook Road
Bristol
BS6 7DA
10Allanbank Road
Kinbuck
Dunblane
FK15 0NH
11 Balvicar
Isle Of Seil
Oban
ARGYLL
26/07/2011
O
25/07/2011
O
22/07/2011
O
12/09/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
30/09/2011
O
06/09/2011
O
19/07/2011
O
19/07/2011
O
30/09/2011
O
19/08/2011
O
16/08/2011
O
16/08/2011
O
01/09/2011
O
18/07/2011
O
01/08/2011
O
Page 98
Dr Tony Bennett
Ms Jill Watkins
Mr Angus Morrison
Jean L Alexander
Miss Kathleen Cowie
Mrs Vivienne Merrick
Tim Wray
Mrs Alison Wray
Mr Cliff Pearn
Miss Rachel Godden
Robert Godden
S Goridge And S Eldnoye
Dr Kate Dunn
Mr John Whitley
Mr Robin Gallamore
J Currie
Mr Fraser Robertson
Sheila Brook
David Brook
Mr Adrian Lough
PA34 4TF
11 Cairnbaan Cottages
Cairnbaan
Lochgilphead
PA31 8SJ
11 Church Lane
Walthamstow Village
London
E17 9RN
11 Coolin Drive
Portree
IV51 9DN
11 Cullipool Village
Isle Of Luing
By Oban
PA34 4UB
11 Donmouth Road
Aberdeen
AB23 8DT
11 Eldridge Close
Pendeford
Wolverhampton
WV9 5PX
11 Hoole Road
Broomhill
Sheffield
S10 5BH
11 Hoole Road
Sheffield
S10 5BH
11 Oak Apple Close
Saltash
Cornwall
11 Scotland Hill
Sandhurst
GU47 8JR
11 Scotland Hill
Sandhurst
Berks
GU47 8JR
11 St Aethans Drive
Burfhead
Moray
IV30 5GP
11 Woolliscroft Ave
Newcastle
ST5 0NR
111 Divinity Road
Oxford
OX4 1LW
112 Derby Road
Melbourne
Derby
DE73 8FL
115 Town Way West
Towyn
LL22 9LF
1173 Gallowgate
Glasgow
G31 4EG
11A Hazelmore Avenue
Newcastle Upon Tyne
NE3 5QL
11A Hazelnut Avenue
Newcastle Upon Tyne
NE3 5QL
12 Dundrenann Cottages
Edinburgh
EH16 5RG
28/07/2011
O
20/07/2011
O
21/07/2011
O
04/08/2011
O
02/08/2011
O
18/07/2011
O
03/08/2011
O
01/08/2011
O
19/07/2011
O
14/07/2011
O
16/08/2011
O
03/08/2011
O
02/08/2011
O
18/07/2011
O
03/08/2011
O
12/09/2011
O
03/08/2011
O
05/08/2011
O
22/08/2011
O
06/09/2011
O
Page 99
Dr Fiona Lough
Mrs Helen Butland
L Bradshaw
Mr Robert Ferguson
Jean Rhoades
Andrea Sturniolo
Miss Pamela Mcleish
Miss Nicola Simmons
Mrs Jackie Simmons
Mrs Dawn Crowe
Mr David Rillie
Mr Tom Gallagher
Mrs Alison Tamea
Mr Hug Kerr
Ms Christine Page
S Teefer
Diane McVeigh
Mr Paul Stanier
Ms. Franka Leehr
12 Dundrennan Cottages
Edinburgh
EH16 5RG
12 Forde Close
Newton Abbot
TQ12 5NN
12 Maida Grove
Fulford Road
York
YO10 4EU
12 Polmont Road
Laurieston
Falkirk
FK2 9QY
12 The Greens
Glencruitten Road
Oban
Argyll
PA34 4DD
125 Clarence Road
London
E5 8EE
1-29 Esplanade Court
Corran Esplanade
Oban
PA34 5PW
13 Broadwater Gardens
Orpington
BR6 7UQ
13 Broadwater Gardens
Orpington
BR6 7UQ
13 Roselea Drive
Glasgow
G62 8HE
13 Wanless Court
Musselburgh
EH21 7QU
13, Moor Rd
Cartland
Lanark
ML117RE
133 Seaton Road
Hemel Hempstead
HP3 9HU
14 Brierie Aveonue
Crosslee
Johnstone
PA6 7BQ
14 Brucehaven Road
Limekilns
Dunfermline
KY11 3HZ
14 Cnoc A Challtuinn
Clachan Seil
By Oban
Argyll
PA34 4TR
14 Tor Close
Waterlooville
Hampshire
PO7 8SU
14, Collinbourne Close
Trentham
Stoke-on-Trent
ST4 8GU
14/8 Roseneath Place
Edinburgh
EH9 1JB
03/10/2011
O
17/07/2011
O
16/08/2011
O
07/08/2011
O
16/09/2011
O
01/09/2011
O
21/07/2011
O
18/07/2011
O
18/07/2011
O
26/07/2011
O
19/07/2011
O
24/07/2011
O
19/07/2011
O
12/09/2011
O
08/09/2011
O
03/08/2011
O
12/09/2011
O
03/08/2011
O
18/07/2011
O
Page 100
Mr Stephen Miller
Name Illegible
Neil Weddell
Dr Inglis Lamont
Susan Wharton
Miss Pamela Ocampo
Sheila Urquhart
Mrs Kim Morgan
A Dechmilemot
Miss Rosanna Forbes
Jenny Underwood
Mrs Maggie Bowie
MR Mark Patton
Miss Seonaid Reid
Mr David Robinson
Ian Whyte
Mr Trevor Taylor
J Walford
Pauline McCluskey
Mr Jock Souter
Mt Tony Walsh
143 Craig Street
Darlington
DL3 6H
144 Bewdley Hill
DY11 6BT
147 Riverstone Way
Northampton
NN4 9QW
148 Sinclair Street
Helensburgh
G84 9AT
15 Balvicar
Seil Island
Oban
Argyll
PA34 4TF
15 Bruce Road
Glasgow
G41 5EN
15 Geils Avenue
Dumbarton
G82 2QJ
15 Hutton Avenue
Hartlepool
TS26 9PW
15 Parker Streeet
Dundee
UK
DD1 5RZ
15 Randolph Crescent
Edinburgh
EH2 7TT
15 Thornhill Terrace
Sunderland
SR2 7JL
15 Victoria Street
Alloa
FK10 2DZ
15 Waincliffe Crescent
15 Waincliffe Crescent
Leeds
LS11 8EU
15/1 Orchard Brae Gardens
Edinburgh
EH4 2HQ
154 Belper Lane
Belper
Derbyshire
DE56 2UJ
16 Combie Court
Glencruitten Road
Oban
Argyll And Bute
PA34 4BY
16 Fairway Gardens
Pendine Park
Gwersyllt
LL11 4XB
16 Fife Road
Darlington
DL3 7SY
16 Rivermead Road
Exeter
EX2 4RL
16 Tinto Drive
Cumbernauld
G68 9BF
16, Eagle Terrace
Woodford Green IG8 9AT
17/07/2011
O
26/08/2011
O
16/08/2011
O
21/07/2011
O
03/08/2011
O
18/07/2011
O
25/07/2011
O
17/07/2011
O
03/08/2011
O
18/07/2011
O
20/10/2011
O
19/07/2011
O
18/07/2011
O
26/07/2011
O
23/07/2011
O
26/07/2011
O
18/07/2011
O
05/08/2011
O
05/08/2011
O
19/07/2011
O
16/08/2011
O
Page 101
Miss Kirsty Dunn
Mr Timothy Elliott
Miss Kristine Bird
Ian Poyner
Professor Jeremy Cresswell
Miss Caroline Warburton
Mr Martyn Tunstall
Jill And Brian Hallett
Ms Deanna Austin-Crowe
Mr James Doonan
Mary Doonan
Mr Stephen Hines
Mr Matthew Mercer
Viktor Bale
Ms Pamela Harrison
J Carr
Mr Gary Henshaw
L G Speers
J Speers
16/3 Chancelot Terrace
Edinburgh
EH6 4SS
16/3 Chancelot Terrace
Edinburgh
EH6 4SS
17 Bouverie Street
Flat 3/3
Glasgow
G14 0PD
17 Fir Grove
Whitehill
Bordon
Hants
GU35 9ED
17 Kestrel Road
Newburgh
Ellon
AB41 6FF
17 Landel Street
Markinch
KY7 6AG
17 North Gyle Park
Edinburgh
EH12 8LE
17 Strone Close
Botley
Oxford
EX2 9SQ
17 Townend Cresc
Stoke Goldington
Bucks
MK168NU
170 Beeches Road
Clydebank
G81 6JH
170 Beeches Road
Clydebank
G81 6JH
174B Iverson Road
London
NW6 2HL
175 West Point
Wellington Street
Leeds
LS1 4JL
18 Harvester Close
Greenleys
Milton Keynes
MK12 6LE
18 Leslie Road
Dorking
RH4 1PS
18 Main Street
Lambley
Nottingham
NG4 4PN
18 Queens Avenue
Ilkeston
DE7 4DL
18 Scaribrick Close
Maghull
Merseyside
L31 9PG
18 Scarisbrick Close
Maghull
Merseyside
L31 9PE
18/07/2011
O
18/07/2011
O
20/07/2011
O
12/09/2011
O
07/01/2012
O
25/07/2011
O
05/09/2011
O
30/09/2011
O
03/08/2011
O
24/07/2011
O
03/08/2011
O
17/07/2011
O
18/07/2011
O
12/09/2011
O
18/07/2011
O
22/08/2011
O
18/07/2011
O
02/09/2011
O
01/09/2011
O
Page 102
Sandra Speers
Brain Heaton
Mr Charlie Fayers
Mr. David Llewelyn
Mrs Ruth Llewelyn
Graham Sparshott
Carina Sparshott
Miss Christine Birch
Pat Leach
Mr John Planck
L MacDonald
Neil MacDonald
Jan Veale
Alex Gibson
Nigel Scriven
Miss Wendy Underwood
Miss Joanne Millett
Mrs Alison Laurie
Miss Diane Elliott
18 Scarisbrick Close
Maghull
Merseyside
L31 9PE
18 Toberonochy Village
Oban
Argyll
PA34 4UE
18 Villiers Lane
Oxford
OX4 4HY
183 Churchill Drive
Glasgow
G11 7EY
183 Churchill Drive
Glasgow
G11 7EY
19 Inverewe Place
Dunfermline
Fife
KY11 8FH
19 Inverewe Place
Dunfermline
Fife
KY11 8FH
19 Queensway
Sunbury On Thames
TW16 6HA
19 Toberonochy
Oban
Argyll
PA34 4UE
19 Wheal Regent Park,
Carlyon Bay
St Austell
PL25 3SP
192 Cedar Drive
Perth
PH1 1RJ
192 Cedar Drive
Perth
PH1 1RJ
1A Girdlestone Road
Headington
Oxford
OX3 7LZ
1A Girdlestone Road
Oxford
OX3 7LZ
2 Alt Na Blathaich
Loch Eck
Dunoon
Argyll
PA23 8SG
2 Brandon Road
Wordwell
Bury St. Edmunds
IP286UL
2 Bryn Road South
Ashton In Makerfield
Wigan
WN4 8QR
2 Corum Place
Blackford
Auchterarder
2 Cruachan Buildings
Lochawe
Dalmally
PA33 1AJ
01/09/2011
O
01/08/2011
O
16/07/2011
O
09/08/2011
O
09/08/2011
O
16/08/2011
O
16/08/2011
O
20/07/2011
O
03/08/2011
O
19/07/2011
O
26/08/2011
O
26/08/2011
O
30/09/2011
O
30/09/2011
O
25/07/2011
O
03/08/2011
O
18/07/2011
O
12/10/2011
O
19/07/2011
O
Page 103
Ms Fiona Maguire
Mrs Mary Williams
Ms Myra Kinghorn
Elaine Plenderleith And Hugh
Plenderleith
Greg Walton
Joshua J Walton
Sam Walton
Mrs Myra Waddell
Mr Martin Waddell
Mr Neal Setterington
Miss Mary Watson
Mr Charlie Hussey
Ms Belinda Magee
Mrs Elizabeth Minton
Mrs Sarah Bealey
Miss Shirley Robson
Mr Christopher Ashley
Mrs Caragh Ashley
Ms Helen Jones
V Robinson
2 Cuddy Lane
Edinburgh
EH10 4TQ
2 Dewberry Close
Stourport on Severn
DY13 8TB
2 Ely Close
Crawley
RH10 5JL
2 Fyne Road
Broughty Ferry
Dundee
DD5 3JF
2 Great Calcroft
Pershore
Worcestershire
2 Great Calcroft
Pershore
Worcestershire
WR10 1QS
2 Great Calcroft
Pershore
Worcs
WR10 1QS
2 Kilbrandon Cottages
Balvicar
Seil
PA34 4RA
2 Kilbrandon Cottages
Balvicar, Isle of Seil
PA34 4RA
2 Kirklands Villas
Baildon
D176HJ
2 Magdala Mews
Edinburgh
EH12 5BX
2 Magdala Mews
Edinburgh
EH12 5BX
2 Mount Hey
Somerton
TA11 7PG
2 New Hall
Bouth
Ulverston
LA128JJ
2 St Georges Cottages
South End, Damerham
Fordingbridge
SP6 3HP
2 St Pancras Close
Dinnington
Sheffield
S25 3RX
2 Yew Tree Villas
Hare Lane
chester
CH3 7EG
2 Yew Tree Villas
Hare Lane, Pipers Ash
Chester
CH3 7EG
2, Kirkhill Court
Broxburn
EH52 6HS
2/1 4 Craiglea Drive
Edinburgh
EH10 5PA
09/09/2011
O
19/07/2011
O
18/07/2011
O
16/08/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
03/02/2013
O
25/07/2011
O
25/07/2011
O
19/07/2011
O
18/07/2011
O
18/07/2011
O
10/09/2011
O
29/07/2011
O
29/07/2011
O
03/10/2011
O
16/08/2011
O
Page 104
Mr Ben Byrne
Mrs Gail Mackay
Mr Andrew McWilliams
mrs Susan Johnston
Mrs Elaine Telfer
Ms Ronnie Mcleod
Mr And Mrs Kitson
Mr Michael Whitley
Mrs. Sheila Costigan
Dr Bandana Malhotra
Miss Sudeshna Choudhury
Mrs Dplali Choudhury
Mr Jamie Inglis
Mrs Emma Inglis
Master Hamish Inglis
Jeremy Inglis
Ms Katrin Josepeit
Mr Robbie Wightman
Mrs. Deborah Mcdonald
B A Fothyill
2/1 46 Bentinck Street
Glasgow
G3 7TT
2/3 North Leith Mill
Edinburgh
EH6 6JY
20 Church Street
Ainsworth
Bolton
BL2 5RT
20 Creag Bhan Village
Oban
pa34 4bf
20 Davies Drive
Alexandria
G83 0UH
20 Ferryfield Gardens
Alexandria
Dunbartonshire
G83 0TB
20 Hunters Grove
Hunters Quay
Dunoon
Argyll
PA23 8LQ
2001 Route De Corps
Saint Martin D'Uriage
38410
201 Crook Ave.
La Grande OR, USA
97850
205 Clarence Lane
London
SW15 5PZ
205 Clarence Lane
London
SW15 5PZ
205 Clarence Lane
London
SW15 5PZ
21 Aird's Crescent
Argyll Square
Oban
PA34 5SJ
21 Aird's Crescent
Argyll Square
Oban
PA34 5SJ
21 Airds Crescent
Oban
PA355SJ
21 Airds Crescent
Oban
Argyll
PA34
21 Aird's Crescent
Oban
PA34 5SJ
21 Clifford Road
North Berwick
EH39 4PW
21 Lindisfarne Road,
Newcastle upon Tyne
Newcastle upon Tyne
NE2 2HE
21 Weald Close
Brentwood
Essex
CM14 4QV
18/07/2011
O
24/07/2011
O
18/07/2011
O
23/07/2011
O
20/07/2011
O
28/07/2011
O
12/09/2011
O
19/07/2011
O
20/07/2011
O
01/08/2011
O
26/07/2011
O
27/07/2011
O
31/08/2011
O
31/08/2011
O
31/08/2011
O
12/08/2011
O
11/08/2011
O
26/07/2011
O
03/08/2011
O
05/08/2011
O
Page 105
Paul Beckett
Phillip Gate
Alan Hinchliffe
Laura Hinchliffe
Mr Bill Gray
Ms Dawn Kelly
Dr Alan McLelland
Birgit Whitmore
Mr Alastair Currie
Mr Justin Williams
Miss Patricia Hughes
Mrs Julie Keetley
Name Illegible
Alex Wellbelove
Mr Jim Anderson
Mr David Burns
Ms Wendy Axford
R Farrell
Mrs Joanne Davenport
21 Weald Close
Brentwood
Essex
CM14 4QV
21/5 Steads Place
Edinburgh
EH6 5DY
210 Rainhill Road
Rainhill
Merseyside
L35 4LD
210 Rainhill Road
Rainhill
Merseyside
L35 4LD
22 Branziert Road North
Killearn
G63 9RF
22 Cell Barnes Lane
St. Albans
AL1 5RA
22 Corlic Way
Kilmacolm
PA13 4JD
22 Cullipool
Luing
PA34 4UB
22 Edinburgh Road
Biggar
ML12 6AX
22 Embleton Road
Lewisham
London
SE13 7DH
22 Hazel Road
Bradmore
Wolverhampton
WV3 7HB
22 Iona Drive
Trowell
Nottingham
NG9 3RF
22 Neville Crescent
Acton
Wrexham
LL12 7HE
220 Tonbridge Road
Wateringbury
Maidstone
Kent
ME18 5NX
224 High Street
Linlithgow
EH49 7ES
23 Clive Rd, Highcliffe
23 Clive Rd
Christchurch
BH23 4NX
23 Clive Road
Highcliffe
Christchurch
BH23 4NX
23 Foulsykes Road
Cambusnethan
Wishaw
23 Kingsmuir Avenue
Preston
PR2 6AG
05/08/2011
O
12/09/2011
O
16/08/2011
O
16/08/2011
O
07/09/2011
O
27/07/2011
O
18/07/2011
O
03/08/2011
O
28/01/2013
O
18/07/2011
O
18/07/2011
O
19/07/2011
O
25/08/2011
O
22/08/2011
O
18/07/2011
O
18/07/2011
O
18/07/2011
O
03/08/2011
O
21/07/2011
O
Page 106
Mrs Victoria Colville
E Vincent
Catherine Vincent
Emma Nicole Vincent
Lucy Gladden
Robert Gladden
Miss Emma Williams
Miss Lucy Smith
Mr David Simpson
Ian McIntyre
Anna Dalliniort And Ben Dalliniort
Rev. Mr. Derek Corner
Ms Judith Wilson
Ms Jeanette Tsang
Dr Rosalind Glasspool
Miss Isabel Miguelez
Mr James Watson
Sam Johnson
Mr Francis Connelly
Mrs Caroline Gwilliam
24 Mill Cottage Park
Newtownards
BT22 2FF
24 Preston Avenue
ME30 2BS
24 Preston Avenue
North Sheilds
Tyne And Weir
NE30 2BS
24 Preston Avenue
North Sheilds
Tyne And Weir
NE30 2BS
24 The Larches
Faversham
Kent
ME13 7SQ
24 The Larches
Faversham
Kent
ME13 7SQ
24/6 Milton Street
Edinburgh
EH8 8HE
240 Coteford Street
London
SW17 8NL
25 Majors Loan
Falkirk
FK1 5QG
25 Stravaig Walk
Paisley
PA2 0RX
25 Toberonochy
Isle Of Luing
Oban
Argyll
PA34 4UE
254 Lime Crescent
Abronhill
Cumbernauld
G67 3PH
26 Clarence Street
Edinburgh
EH3 5AF
27 Guildford Grove
London
SE10 8JY
27 Banavie Road
Glasgow
G11 5AW
27 Baxter Park Terrace
Dundee
dd4 6nr
28 Sandwell Crescent
Kirkcaldy
KY1 1GH
29 Barclay Park
Aboyne
Aberdeenshire
AB34 5JF
29 Colquhoun Road
Milton
Dumbarton
Glasgow
G82 2TH
29 Hilltop Road
Whyteleafe
CR3 0DF
18/07/2011
O
16/08/2011
O
16/08/2011
O
16/08/2011
O
05/08/2011
O
05/08/2011
O
18/07/2011
O
18/07/2011
O
24/07/2011
O
11/10/2011
O
05/08/2011
O
17/07/2011
O
02/08/2011
O
19/07/2011
O
23/07/2011
O
27/07/2011
O
05/09/2011
O
05/08/2011
O
03/08/2011
O
03/08/2011
O
Page 107
Mrs H Cameron
Jeremy Iles
Ms Katryn Mercer
Miss Laura Gamble
Mrs Margaret MacLachlan
Mr Willie Fulton
Mr Richard Goodson
Mr Ben Mitchell
Ms Lindsay Gilmour
Mrs Anne-Marie Geoffrion-Pfeil
Holly Abrol
James Robertson
Mr Peter Mackie
Mr Andrew Newton
Mr Michael Long
Donald Manson
Miss Eala Williams
Miss Elodie Megaoui
Mr Julien Valentin
3 Ardloch Cottages
Glenburn Road
Ardrishaig
Argyll
PA30 8EU
3 Barrhill Close
Great Barr
Birmingham
B43 6LS
3 Brookside
Sutton
Ely
Cambs
3 Chesnut Avenue
Radley College
Abingdon
OX14 2HS
3 Claymhor, Hillview Drive
Corpach
Fort William
PH33 7LS
3 Drinishader
Isle Of Harris
HS3 3DX
3 High Grizebeck
Grizebeck
Kirkby-in-Furness
LA17 7XJ
3 Kilmun Court
Dunoon
pa23 8sf
3 Lyppiatt Road
Bristol
BS5 9HW
3 Rue De Walbourg
Schiltigheim
F 67300
3 Ryefield Close
Solihull
West Midlands
B91 1PP
3 St Michaels Knowe
Garelochhead
Helensburgh
G84 ODQ
3 Stanley Avenue
Wallasey
CH45 8JN
3 The Avenue, Southlands
Haxby
York
YO322PD
3 Walkers Mount
Meanwood
Leeds
LS6 2SD
3 West Street
Dunoon
Argyll
PA23 8EB
3 Whin Bank
Clachan Siel
Oban
3/1 Coinyie House Close
Edinburgh
EH1 1NL
3/1 Coinyie House Close
Edinburgh
EH1 1NL
12/09/2011
O
03/08/2011
O
18/07/2011
O
18/07/2011
O
21/07/2011
O
18/10/2011
O
18/07/2011
O
20/07/2011
O
01/08/2011
O
18/07/2011
O
16/08/2011
O
25/07/2011
O
03/08/2011
O
18/07/2011
O
20/07/2011
O
08/08/2011
O
03/08/2011
O
18/07/2011
O
18/07/2011
O
Page 108
Mr Tom Learoyd
Miss Amy Ferguson
Miss N Tobin
Mr Peter Dutton
Guy Lidbury
Ms Anita Machin
Mrs Carolyn Evans
Mr Alan Hawkins
Mrs C Cardy
Mr MIke Redhead
Miss Heather Hutchings
David Milburn
Mr Boyd Tunnock CBE
3/2, 3 Dowanside Road
Glasggow
G12 9YB
3/6 Warrender Park Terrace
Edinburgh
EH91JA
30 Cornwall Road
Manchester
M437PR
30 Toberonochy
Island of Luing
By Oban
PA34 4UE
31 North St
Maldon
Essex
England
CM9 5HH
310
Design House
Manchester
M4 1BH
310
Yewdale
Skelmersdale
WN86ES
32 Barr Mor View
Kilmartin
PA31 8UN
326 Millfield Hill
Erskine
PA8 6JN
34 Derrymore Road
Willerby
HU10 6ES
34 Drakeley Court
Aubert Park
London
N5 1TT
34 Newquay Close
Nuneaton
Warwickshire
CV11 6FH
34 Old Mill Road
Uddingston
Glasgow
G71 7HH
01/08/2011
O
24/07/2011
O
18/07/2011
O
22/07/2011
O
05/08/2011
O
18/07/2011
O
26/10/2011
O
20/07/2011
O
17/07/2011
O
04/08/2011
O
03/08/2011
O
03/08/2011
O
02/09/2011
O
12/09/2011
O
02/08/2011
O
28/07/2011
O
22/07/2011
O
10/09/2011
O
18/08/2011
O
18/08/2011
O
Gerry Taylor
Ms Elke Braun
Mr Paul Branney
Mrs Wendy Kirby
Mrs Lois Skilleter
Mr Larry Rumbol
Mrs Nele Andersch
3446 Plymouth Road Victoria B.C. Canada
35 Weavers Way
Tillicoultry
FK13 6BD
36 Millar Street
Carnoustie
DD7 7AT
36 Rowallan Road
London
SW6 6AG
36, Skipton Road
Ilkley
LS29 9EP
37 Daniells Walk
Lymington
SO41 3PP
37 Daniells Walk
Lymington
SO41 3PP
Page 109
Ms Colette Coleman
Mr Alan Smith
Miss Doune Fairfax
Miss Jo Fowler
Belcho Petrov
Mr Stephen Mawdsley
Mr Roy Morrison
Mrs June Morrison
T Cunliffe
L Cunliffe
Dr Denise Cowley
Mrs Bryony Wells
Miss Hannah James
Dr Emeka Mosanya
Ms Melanie Berard
Mr Eamonn Corking
Clare E Metcalfe
Daniel Robinson
Ian Callaghan
Mr James Macleod
Mr Paul Douch
37 Hawthorne Gardens
Hockley, Essex
SS5 4SW
37 High St.
Dunbar
EH42 1EW
37/4 William Street
Edinburgh
EH3 7LW
38 Kinneil Drive
Bo'ness
EH510LY
38 Norbroke Street
London
W12 0QX
388 Newchurch Road
Rawtenstall
Rossendale
BB47SN
39 Blackhill Drive
Helensburgh
G84 9AF
39 Blackhill Drive
Helensburgh
G84 9AF
39 St John Street
Newton Le Willow
Merseyside
WA12 9NW
39 St John Street
Newton Le Willows
Merseyside
WA12 9NW
39 Toberonochy
Toberonochy Village Luing
Oban
PA34 4UE
3a Fairfax Road
Leeds
LS11 8SY
3A Stone Villas
Leeds
LS6 4AA
3c Welbeck Mansions
London
NW6 1QX
3F2 34 Spottiswoode rd
Edinburgh
EH91BL
4 Belgrave Road
Billericay
CM12 0TX
4 Coppy Bridge Drive
Rochdale
Greater Manchester
England
4 Cranley Drive
Edinburgh
EH10 5PA
4 Delamore Way
Oxford
OX2 9HZ
4 Lonan Drive
Oban
Oban
Argyll And Bute
PA34 4NN
4 Marsh Lane, Somerleyton
Lowestoft NR32 5QX
18/07/2011
O
14/09/2011
O
19/07/2011
O
17/07/2011
O
10/08/2011
O
18/07/2011
O
24/07/2011
O
22/07/2011
O
16/08/2011
O
16/08/2011
O
17/07/2011
O
20/07/2011
O
18/07/2011
O
19/07/2011
O
19/07/2011
O
09/08/2011
O
26/08/2011
O
16/08/2011
O
11/10/2011
O
19/07/2011
O
27/07/2011
O
Page 110
B Currie
Prof Roger Waigh
Mrs Tina Avery
Dr Brice Avery
Ms Jennifer Willis
Bret Hopping
Mrs G Ringrose
Mrs Isabel Carter
Mr Philip Carter
Mr Neil Kennedy
Mrs H R Graham
Ms. Sara Reader
Mr. Sean Nore
Mr Hugh Gray
Ms Alessia Kockel
Mr Roderick Millar
Mr Stuart McLoughlin
Ms Melanie McLoughlin
U Richardson
W Richardson
Miss Edna Ewan
4 St Georges Crescent
RHYL
Wales
4 The Meadows
Helensburgh
G84 9EG
4 Toberonochy
Isle of Luing
PA34 4UE
4 Toberonochy
Isle of Luing
EH9 1LW
4/31 Forrest Rd
Edinburgh
EH1 2QP
40 Fir Copse Road
Parbrook
PO7 5HZ
40 Gadebridge Lane
Hemel Hempstead
HP1 3HF
41 Leeds Old Road
Heckmondwike
WF16 9AA
41 Leeds Old Road
Heckmondwike
WF16 9AA
41 Marlborough Avenue
Glasgow
G11 7BP
41 Toberonochy Village
Toberonochy
Isle Of Luing
PA34 4UE
410 N Monroe
Gardner
60424
412 34th St
West Des Moines
50265
42 Cullipool
Isle of Luing
Oban
PA34 4UB
42 Mersham Drive
London
NW9 9PN
42 Moray Place
Edinburgh
EH3 6BT
43 Church Road
Trull
Taunton
TA3 7LG
43 Church Road
Trull
TA3 7LG
43 Fairstead
Birch Green
Skelmersdale
Lancashire
WN8 6RB
43 Fairstead
Birch Green
Skelmersdale
WN8 6RB
44 Eastside Drive
Westhill
AB32 6QN
12/09/2011
O
19/07/2011
O
25/07/2011
O
21/07/2011
O
19/07/2011
O
12/09/2011
O
25/07/2011
O
25/07/2011
O
25/07/2011
O
13/08/2011
O
03/08/2011
O
18/07/2011
O
08/09/2011
O
04/08/2011
O
18/07/2011
O
19/07/2011
O
21/07/2011
O
20/07/2011
O
16/08/2011
O
16/08/2011
O
17/07/2011
O
Page 111
Mr John Lowe
Mrs Ann Turner
Ms. Sara Macdonald
Mrs Sheila Johnson
Mr Joe McIntyre
Mrs Cathy McIntyre
Ms Geraldine Joaquim
Mr Stephen Tame
Miss Meilisa Blackham
Mrs Sheila Blackham
C J Holby
K Holby
Mr Peter Tickle
Miss Nicola McMurtrie
Mr David Dougal
Mr & Mrs John and Fiona Watson
Mr Greg Rust
Mr Colin Thirlwall
D Mitchell
J Mitchell
44 Woodside Drive
Forres
IV36 2UF
45 Hillhead
Coylton
Ayrshire
KA6 6JT
46 Bentinck St.
Glasgow
G37TT
46 Cleveland Place
Peterlee
SR8 2PA
46 MacLeod Drive
Helensburgh
G84 9QU
46 MacLeod Drive
Helensburgh
G84 9QU
46 Sturt Road
Haslemere
GU27 3SD
46 West Street
Devon
TQ13 7DU
47 Hampton Hill
Wellington
Telford
TF1 2ER
47 Hampton Hill
Wellington
Telford
TF1 2ER
47 Manor Road
South Woodham Ferrers
Essex
CM3 5PT
47 Manor Road
South Woodham Ferrers
Essex
CM3 5PT
47, Brown Lees Road
Biddulph
Stoke-on -trent
ST8 6PJ
48 Edmund Kean
East Kilbride
G74 3RG
49 Balfour Street
Edinburgh
EH6 5DP
49 Broompark Drive
Newton Mearns
Glasgow
G77 5DZ
49 Hayes Hill
Bromley
BR2 7HN
49 London Road
Godmanchester
PE29 2HZ
493 Lodge Lane
Solihull
West Midlands
B92 8NT
493 Lodge Lane
Solihull
West Midlands
B92 8NT
25/07/2011
O
13/09/2011
O
18/07/2011
O
18/07/2011
O
25/07/2011
O
25/07/2011
O
18/07/2011
O
18/07/2011
O
17/07/2011
O
17/07/2011
O
16/08/2011
O
16/08/2011
O
03/08/2011
O
29/07/2011
O
16/09/2011
O
22/08/2011
O
22/07/2011
O
23/08/2011
O
16/08/2011
O
16/08/2011
O
Page 112
Mr James Heward
Mr Graham Muir
Margarithe Haffner
Mr Roddy Campbell
Dr Mark Steer
S E Oaly
Mr Kim Ley
Mr Frank Ford
Miss Victoria Ashton
Mrs Susan Eldred
Mr Chris Eldred
Martha, Molly And S Eldred
Mr Thomas Wilson
Reverand Frank Front
Ms Janine Ogilvie
Miss Harriet Carp
Mr Henry Procter
Claire Matson
Dr Jeremy Bass
Mr Paul Leitch
A McNally
5 Benvoullin Gardens
Oban
PA34 5DL
5 Calside Avenue
Paisley
PA2 6DD
5 Church Path
Chiswick
W4 5BL
5 Drinishader
Harris
HS33DX
5 Elberton Road
Olveston
BRISTOL
BS35 4DD
5 Matthews Yard
Reepham
Norfolk
NR10 4NF
5 Mount Close
Bristol
BS36 2DD
5 Pennine View
Glasson Dock
Lancaster
LA2 0AS
5 Randle Drive
Sutton Coldfield
b75 5lh
5 Stanhope St
Hereford
HR4 0HA
5 Stanhope St
Hereford
HR4 0HA
5 Stanhope Street
Hereford
HR4 0HA
5 Stellhead
Avenue
New Cumnock
KA18 4JT
5 Toberonochy
Oban
PA34 4UE
5 Tynemouth way
Heaton
Newcastle
NE6 2RZ
5 Webbs Road
London
SW11 1XJ
5, The Sycamores,
Glossop
SK13 2BS
50 Bellahouston Drive
Glasgow
G52 1HQ
51 Tinto Road
Newlands
GLASGOW
G43 2AH
51 Woodhall Bank
Edinburgh
EH13 0HL
52 Fen End Lane
Spalding
Lincs PE12 6AD
19/07/2011
O
22/07/2011
O
26/08/2011
O
19/10/2011
O
18/07/2011
O
16/09/2011
O
18/07/2011
O
26/07/2011
O
02/08/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
20/07/2011
O
26/07/2011
O
19/07/2011
O
22/07/2011
O
18/07/2011
O
12/09/2011
O
26/07/2011
O
14/09/2011
O
12/09/2011
O
Page 113
R McNally
Miss Cherie Bettison
Mr Stephen Outhwaite
Mr John Hanmer
Name Illegible
Mr Richard Gonzalez
Mr Daniel Sidoli
Mr Ben Burns
Mr Craig Muirhead
Mr David Pearson
Mr Duncan Macdonald
Roy And June Stove
Mr Charlie Tomlinson
Mr Simon Gurney
Mr Barry Carter
Andrew Forrester
Daniel And Celia Hughes
Mr David Shenton
Miss Weronika Chaberko
52 Fen End Lane
Spalding
Lincs
PE12 6AD
52 Glen Gardens
Callander,
FK17 8ES
52 Woodlands Drive
Harrogate
HG2 7AX
52, Broomleaf Road,
Farnham,
GU9 8DQ
53 Churchfields
Milltown
Dublin 14
Republic Of Ireland
535 Portswood Road
Southampton
so173sa
54 Halstead Road
Winchmore Hill
London
N21 3DS
54 Thames Close
Hampton
TW12 2ET
57 Hopefield Road
Blackburn
EH477HX
58 Cambridge Road
Crosby
Lverpool
L23 7TZ
58 Cloan Crescent
Bishopbriggs
Glasgow
G64 2HW
6 Acha
Balvicar
Near Oban
PA34 4RJ
6 Buckingham Street
Hillhead
Glasgow
G12 8DL
6 Cross Rd
Leamington Spa
CV32 5PB
6 Elm Court
Elmdon
Saffron Walden
CB11 4NP
6 Havelock Road
Croydon
Surry
CR0 6QP
6 High Street
Dollar
Scotland
FK14 7AY
6, Ninian's Rise
Kirkintilloch
Glasgow
G66 3HU
6/3 Montague St
Edinburgh
EH8 9QU
12/09/2011
O
19/07/2011
O
16/08/2011
O
17/05/2012
O
26/08/2011
O
02/08/2011
O
19/07/2011
O
19/07/2011
O
18/07/2011
O
04/08/2011
O
16/08/2011
O
03/08/2011
O
25/07/2011
O
19/07/2011
O
18/07/2011
O
03/08/2011
O
01/09/2011
O
03/08/2011
O
18/07/2011
O
Page 114
Sindy Lau
Andrew Hill
Michael Walsh
Belinda Faulkner
Ricardo Telmo Fernandes
Mr Chris Owen
D Griffin
R B Griffin
Name Illegible
T Entwistle
Mr Ian Sharpe
Alison Barnes
Mrs Marian Hollings
Mrs Jennifer Petrie
Pamela Hughes
Roger Hughes
Mrs Peggy Mack
Jonathon Ashworth
61 Finisterne Parade
Port Marine
Portishead
BS20 7JY
61 Finisterne Parade
Portmarine
Portishead
Bristol
BS20 7JY
61 Maes Y Wennol
Miskin
Pontyclun
CF72 8SB
61 Princes Street
Stone
Staffordshire
ST15 8HY
61 Princes Street
Stone
Staffordshire
ST15 8HY
63 Bath Road
Eastington
Stonehouse
GL10 3AY
63 Beswick Gardens
Rugby
Warwickshire
CV22 7PR
63 Beswick Gardens
Rugby
Warwickshire
CV22 7PR
63 Carlton Way
Glazebrook
Warrington
WA3 5BG
63 Carlton Way
Glazebrook
Warrington
WA3 5BG
63, Black Butts Lane
Walney Island
Barrow-in-Furness
LA14 3JZ
67 Simonside Terrace
Heaton
Newcastle UponTyne
NE6 5LF
670 Bolton Road
BRadford
BD3 0ND
68 Auchmithie
Arbroath
DD11 5SQ
7 Ballaig Avenue
Bearsden
Glasgow
G61 4HA
7 Ballaig Avenue
Bearsden
Glasgow
G61 4HQ
7 Blackhouse Avenue
Newton Mearns
Blackhouse Avenue
G77 5HU
7 Clarence Grove
Leeds LS18 4LA
16/09/2011
O
16/09/2011
O
10/08/2011
O
05/08/2011
O
05/08/2011
O
07/09/2011
O
10/08/2011
O
10/08/2011
O
16/08/2011
O
16/08/2011
O
26/07/2011
O
12/09/2011
O
10/08/2011
O
18/10/2012
O
03/08/2011
O
03/08/2011
O
22/07/2011
O
20/10/2011
O
Page 115
Mr Jamie Dyer
Mrs Cheryl Power
Mr Kurt Leech
Declan And Mairead Currie
Mr Anthony Howard
K E Mallalratt
Mr John Travers
Libby Lawes
Paul Goddard
Mr Alex Campbell
Mr Michael Walters
Mr Bill Waugh
Amanda Fairclough
Mrs Julia Galbraith
Mr Robert Fraser
C Wilson
A E Wilson
J Wilson
7 Cooper Cottages
Barrock
Thurso
KW14 8SZ
7 Foxgrove Avenue
7 Foxgrove Avenue
Beckenham
BR3 5BA
7 Grangeway
Handforth, Wilmslow
SK9 3HY
7 Grosvenor Avenue
Rhyl
Wales
LL18 4HA
7 Herontye Drive
East Grinstead
RH19 4LR
7 Myrtle Street
Retford
Nottinghamshire
DN22 7BS
7 Park Place
Thackley
BD10 0TG
7 Queens Road
Clevedon
BS21 7TH
7 Roy Avenue
Ipswich
Suffolk
IP3 8LN
7 Rufford Grove
Bingham
Nottingham
NG13 8RH
7 St James Close
Baildon
Shipley
Bradford
BD17 6HF
7 Thorne Court
North Berwick
EH39 4RU
7 Time Park
Prescot
L35 7NU
7 Toberonochy
Isle of Luing
Oban
PA34 4UE
7
Langhill Farm Cottages
Roslin
EH25 9ST
71 Moore Close
Claypole
Newark
NG23 5AU
71 Moore Close
Claypole
Newark
Notts
NG23 5AU
71 Moore Close
Claypole
Newark
Notts
NG23 5AU
17/07/2011
O
18/07/2011
O
18/07/2011
O
12/09/2011
O
18/07/2011
O
10/08/2011
O
26/07/2011
O
19/07/2011
O
03/08/2011
O
03/08/2011
O
20/07/2011
O
26/07/2011
O
01/09/2011
O
29/07/2011
O
18/07/2011
O
26/08/2011
O
26/08/2011
O
26/08/2011
O
Page 116
Mr Gregory Chauvet
Mr Roger Green
Ms Joy Williams
Leigh Gordon
Mr Colin Iain Macrae
Graham Batty
Andy McDonald
Mr Carl Wright
Name Illegible
Miss Shona Forbes
Mr Stephen Lee
Agnes M M Connelly
Mrs Carol Ramsey
Ms A Otto
J And G Hallan
Miss Judith Wroe
Mr Owen Merrick
Miss Sanccia Thomas
Mr Peter Wrate
Evie Weir
73 Hanson Street
Glasgow
G31 2HF
73 Leigh Hall Road
Leigh-on-Sea
SS9 1QZ
74 Albion Street
Wirral Citizens Advice Bureau
Wallasey
CH45 9JH
74 Angle Park Terrace
Edinburgh
EH11 2JP
75 Riddochhill Road
Blackburn
EH477EZ
76 Cardinal Avenue
Boreham Wood
Herts
WP6 1SH
76 Simonside Terrace
Heaton
Newcastle Upon Tyne
NE6 5LF
77 Oawood Road
Bricket Wood
AL2 3QB
78 Springwood Avenue
Stirling
FK8 2PE
79 Hollinhall Street
Greenacres
Oldham
OL4 3EH
8 Ash Lane
Wells
BA5 2LU
8 Balvicar
Isle Of Seil
By Oban
Argyll
PA34 4TF
8 Belmont Close
Branton
Doncaster
DN3 3PU
8 Harwill Grove
Churwell
Leeds
LS27 7QH
8 Hill View
Whailey Bridge
High Peak
Derbyshire
SK23 7BG
8 Jennings Avenue
Salford
M5 3JR
8 Johnstone Street
Alva
FK12 5AE
8 Kingfisher Brae
Livingston
EH54 6UD
8 Kirkhill Drive
Oldmeldrum
AB51 0FP
8 Phoenix Court
Chertsey Road
18/07/2011
O
01/09/2011
O
18/07/2011
O
03/08/2011
O
03/08/2011
O
05/08/2011
O
12/09/2011
O
19/07/2011
O
26/08/2011
O
18/07/2011
O
20/07/2011
O
01/08/2011
O
18/07/2011
O
19/07/2011
O
01/08/2011
O
19/07/2011
O
03/09/2011
O
02/08/2011
O
23/07/2011
O
16/08/2011
O
Page 117
Lee Weir
J Taylor
Mrs Linda Brown
Mrs R D Reading
Sylvia Jordan And Colin Jordan
Heather Noble
Ian Noble
Miss Heather Forbes
Mr Shaun Ritchie
Miss Karen Davies
Naomi Burgoyne
Mr Ciaran Hoy
Miss Fern Lear
Mr Daniel Lear
Mr Michelle Lear
Mr Robin Lear
Mr John Mark Mitchell
Ms Barbara Nock
Alison Reynolds
Lower Feltham
Middlesex
TW13 4RN
8 Phoenix Court
Chertsey Road
Lower Feltham
Middlesex
TW13 4RN
8 Robin Hood Close
St Johns
Woking
GU21 8SS
8 Seaview Terrace
Easdale
Oban
PA34 4RG
8 Stafford Street
Helensburgh
G84 9JU
8 Sundown Avenue
Littleover
Derby
DE23 1GY
80 Hutton Avenue
Hartlepool
TS26 9PR
80 Hutton Avenue
Hartlepool
TS26 9PR
80 North Bughtlinside
Edinburgh
EH12 8YB
81 Haberdasher Street
London
N16EH
83 Folly Lane
Swinton
Manchester
M27 0DB
84 Martin Close
Deancross Street
London
E1 2QT
84/6 Hawthornvale
Edinburgh
EH6 4JX
85, Sunningdale Close
Warrington
WA5 4NS
85, Sunningdale Close
Warrington
WA5 4NS
85, Sunningdale Close
Warrington
WA5 4NS
85, Sunningdale Close
Warrington
WA5 4NS
87/5 Restalrig Road South
Edinburgh
EH7 6JD
89 Braehead Cresent
Stonehaven
ab39 2pp
89 Saville Road
Whiston
Rotherham
South Yorkshire
S60 4DZ
16/08/2011
O
26/08/2011
O
21/07/2011
O
03/08/2011
O
16/09/2011
O
26/08/2011
O
26/08/2011
O
17/07/2011
O
03/08/2011
O
17/07/2011
O
01/09/2011
O
16/07/2011
O
18/07/2011
O
18/07/2011
O
18/07/2011
O
18/07/2011
O
08/09/2011
O
18/07/2011
O
12/09/2011
O
Page 118
John Reynolds
Nick Gilmour
Dr Tom Hurst
Mr Adam Cheetham
Mrs Kate Harris
Claire MacLeod
M Mawld
Ms Susan Yates
William Jones
Ms Janet Harbidge
Mr Osbert Lancaster
Mr Martyn Webster
Mr Paul DAnaleze
Mr Gordon Laing
Mr Frederick Mckenna
Dr Nicola MacLeod
Ms Vicky Stirling
Mrs Pat Blunsden
Neil J McLean
Ms G W Stewart
89 Saville Road
Whiston
Rotherham
South Yorkshire
S60 4EE
9 Balvicar
Seil
PA34 4TF
9 Bristol Ave
Manchester
M19 3NU
9 Buttercup Avenue
Donisthorpe
Swadlincote
DE12 7RR
9 Buttercup Avenue
Donisthorpe
Swadlincote
DE12 7RR
9 Citadel Crescent
Stromness
Orkney
KW16 3EL
9 Citadel Crescent
Stromness
Orkney
KW16 3EL
9 Clough Lane
Grasscroft
Odham
OL4 4EW
9 Elleniheich
Fasdale
Oban
Argyll
PA34
9 Princes Street
Stirling
FK8 1HQ
9 Sandford Gardens
Edinburgh
EH15 1LP
9 Whittingehame Drive
GLASGOW
G12 0XS
91 Fotheringay Road
Glasgow
G41 4LH
93 Falkirk
FK2 9DH
93 Hardshaw Street
St Helens
WA10 1JR
97 Lower Granton Road
Edinburgh
EH5 1ER
9A St Vincent Street
Edinburgh
EH3 6SW
Achabeag
Cuan Rd
Balvicar
PA34 4RJ
Achaleven Farm
Connel
Oban
PA37 1PF
Achnaseilach
Clachan Seil
12/09/2011
O
01/08/2011
O
25/07/2011
O
30/07/2011
O
30/07/2011
O
03/08/2011
O
03/08/2011
O
30/07/2011
O
08/08/2011
O
29/07/2011
O
22/07/2011
O
16/08/2011
O
25/07/2011
O
20/07/2011
O
18/07/2011
O
16/07/2011
O
19/07/2011
O
18/07/2011
O
03/08/2011
O
01/08/2011
O
Page 119
K W Butler
Annika Niellweweme
C Derriks
Christopher Dimonpaulos
David Carmichael
Ellen De Baare
Eva Arents
Fam Van Leyenhurst
Freeh Van Der Engel
Hannah Link
Jaap De Baare
Jane Maskell
Jelmer Krom
Jenny Underwood
Jirgen Rembold
Lorene Korper
Maxi Rembold
Miguel Fausino
Weiner Allee
Miss F Morrison
Mrs Ann Wilson
Ms Tina Jordan
Name Illegible
Thiis Houmans
Mr Murdoch Baxter
Mrs Janice Baxter
Sheila Downie
Richard Pierce
Ms Carol Collis
By Oban
Argyll
PA34 4TJ
Achraich
Clachan Seil
By Oban
Argyll
PA34 4TN
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Address Illegible
Air Tir
Balvicar
Isle Of Seil
PA34 4TF
Aite Fois
Clachan Seil
Oban
PA34 4QZ
Alltbeath, Musdale Road
Kilmore
Oban
PA34 4XX
Alma
Cullipool
Isle Of Luing
Argyll
PA34 4TX
Amberhout 46
1507 EE Zaandam
The Netherlands
Ampfield
Clachan Seil
By Oban
PA34 4TL
Ampfield
Clachan Seil
By Oban
PA34 4TL
An Cala
Isle Of Seil
Argyll
PA34 4RF
An Cala
South Cuan
Isle Of Luing
PA34 4TU
An Fhuaran
Clachan Seil
An Fhuaran
Oban
PA34 4TL
05/08/2011
22/08/2011
22/08/2011
16/08/2011
10/08/2011
16/08/2011
26/08/2011
16/08/2011
03/08/2011
01/09/2011
16/08/2011
02/09/2011
22/08/2011
26/07/2011
01/09/2011
22/08/2011
01/09/2011
10/08/2011
16/08/2011
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
01/08/2011
O
25/07/2011
O
20/07/2011
O
05/08/2011
O
03/08/2011
O
29/07/2011
O
03/08/2011
O
02/08/2011
O
18/08/2011
O
01/08/2011
O
Page 120
Mr Mike Williams
Mrs Denys Mathieson
Dr Peter Thorpe
Dr Vivien Johnston
Baba Gana Kasim
James Lawson
Christian Taylor
Name Illegible
Mrs K Prichard
Mr Andy Thornton
Mrs Marjie Thornton
Mrs Sabina Struthers
Mr A J Struthers
Charles Struthers
Frances Hill
E B Haran
I E Davies
Annesbrook
2 Dewberry Close
Stourport-On-Severn
DY13 8TB
Appin House, appin, argyll
Appin
PA38 4BN
Ar Baile
Clachan Seil
PA34 4TJ
Ard Shona
Blackmill Bay
Luing
PA34 4TZ
Ard Shona
Blackmill Bay
Luing
By Oban
PA34 4TZ
Arden-Beag
7 Station Road
Craigendoran
Helensburgh
G84 7BG
Ardencaple House
Isle Of Seil
Oban
Argyll
PA34 4TN
Ardencaple
Isle Of Seil
By Oban
Argyll
PA34 4TN
Ardene
Harrietfield
Perth
PH1 3TD
Ardenlinne
Ganavan Rd
Oban
PA34 5TU
Ardenlinne
Ganavan Road
Oban
PA34 5TU
Ardmaddy Castle
Balvicar
Oban
PA34 4QY
Ardmaddy Castle
Oban
PA34 4QY
Ardmaddy Castle
By Oban
Argyll
PA34 4QY
Ardross
Clachan Seil
Oban
PA34 4TL
Ardtun
Clachan Seil
Oban
Argyll
PA34 4TL
Ardtun
Clachan Seil
Oban
18/07/2011
O
04/08/2011
O
28/07/2011
O
01/08/2011
O
04/08/2011
O
25/08/2011
O
04/08/2011
O
04/08/2011
O
20/07/2011
O
24/07/2011
O
24/07/2011
O
26/07/2011
O
26/07/2011
O
05/08/2011
O
02/08/2011
O
03/08/2011
O
03/08/2011
O
Page 121
A Gardiner
Mr Maurice Wilkins
Mrs Elizabeth Maclean
Mrs Linda Lancaster
Miss Elspeth Campbell
Georgina M C McCrae
Mr. Kees Rodenburg
S Brown
Mr Ian Provan
Mr Jamie Mellor
Antoinette N M Mitchell
Antoinette NM Mitchell
Nigel A Mitchell
Jim Bell
Liz Newton
Mr Graham Johnston
Argyll
PA34 4TL
Ardtun
Clachan Seil
Oban
PA34 4TL
Arduaine Garden
Arduaine
Oban
PA34 4XQ
Aros Ard
Croft Road
Oban
PA34 5JN
Ashbeck
Brow Edge Road
Backbarrow
LA12 8QT
Asknish Cottage
Arduaine
by Oban
PA34 4XQ
Auchnagoul Cottage
Inveraray
Argyll
PA32 8XT
BadabrieTramore
Banavie
Fort William
PH33 7LX
Ballachan Farmhouse
Isle Of Seil
By Oban
Argyll
Balliemore
Castleton
Lochgilphead
PA32 8RU
Barndromin Farm
Knipoch
Oban
PA34 4QS
Barochreal
Kilninver
By Oban
PA34 4UT
Barochreal
Kilninver
Oban
Argyll And Bute
PA34 4UT
Barochreal
Kilninver
Oban
Argyll And Bute
PA34 4UT
Basement Flat
15 Hampton Park
Bristol
BS6 6LG
Basement Flat
15 Hampton Park
Bristol
BS6 6LG
Beck House
April Rise
Macclesfield
SK10 3PJ
02/08/2011
O
01/08/2011
O
20/07/2011
O
18/07/2011
O
25/07/2011
O
03/08/2011
O
17/07/2011
O
01/08/2011
O
27/07/2011
O
22/08/2011
O
28/07/2011
O
21/02/2013
O
21/02/2013
O
03/08/2011
O
03/08/2011
O
23/07/2011
O
Page 122
Mr John Landale
Mrs. Xandra Van Der Knaap
Mrs A P Bevis
Mr Michael Handley
Miss Philippa Handley
Dr Elizabeth Henderson
Mr John Gould
Mrs J Gould
Mrs Helen Smith
Linda Broeliema
Mr Ian Ross
Ms Alison Prince
Mr Andrew Nicol
Mr. Robert Jonsen
Dr Andy Walker
Alistair Walker
Catriona Walker
Judge Jeremy Duerden
Berandhu
Appin
PA38 4DD
Boomweidelaan 69
Schore
4423AN Netherlands
Braefoot Farm
Balvicar
Isle Of Seil
Oban
Argyll And Bute
PA34 4RA
Bragleenbeg
Kilninver
Oban
Argyll And Bute
PA34 4UU
Bragleenbeg
Kilninver
PA34 4UU
Braidhurst Cottage
Kirk Brae
Helensburgh
G84 8NP
Brown Edge Road
Buxton
Sk17
Brown Edge Road
Buxton
SK17
Brunstane Gardens
Penicuik
EH26 9AA
Burg De Bordesstr 74
1404 G2 Bussum
The Netherlands
Burnbank
Ardbroilach Road
Kingussie
PH21 1JX
Burnfoot
Whiting Bay
Isle of Arran
KA27 8QL
Bute Estate
Mount Stuart
Rothesay
PA20 9LR
c/o McNaughton
41 Plann Road, Knockentiber
Kilmarnock
KA2 0EN
C/o Scottish Anglers National Assocaition Ltd
The Pier
Loch Leven
Kinross
KY13 8UF
Cairn Ryan
Chapel Brae
Braemar
Aberdeenshire
AB35 5YT
Cairn Ryan
Chapel Brae
Braemar
Aberdeenshire
AB35 5YT
Caladh
17 Lower Cribden Avenue
08/09/2011
O
19/07/2011
O
26/07/2011
O
15/08/2011
O
15/08/2011
O
19/07/2011
O
18/07/2011
O
18/07/2011
O
10/09/2011
O
03/08/2011
O
26/07/2011
O
18/07/2011
O
27/07/2011
O
29/07/2011
O
16/08/2011
O
05/08/2011
O
05/08/2011
O
23/07/2011
O
Page 123
Rossendale Lancs.
BB4 6SW
Dr I Ramsay
Sandra Allan
Mr Robert Fleck
D S Nicol
Mr Jon Close
Mrs Christine Irvine
Mrs M Ann And Mr D Manson
Mr John Jordan
Philip Maskell
Ms Simone Van Dijl
Brenda McGeoch
Wendy And John Mattingley
Mr Peter Stott
Mr David Stott
Mrs Helen Glennie
Mr David Glennie
Calzieveg
Braco
Perthshire
FK15 9RD
Calzieveg
Braco
Perthshire
FK15 9RD
Camusdarach
Kilmelford
PA34 4XA
Carraig
Clachan Seil
By Oban
Argyll
PA34 4TL
Carsaig House
Tayvallich
Lochgilphead
PA31 8PN
Ceol Mara
Glencoe
Ballachulish
PH49 4HS
Ceol Mara
3 West Street
Dunoon
Argyll And Bute
PA23 8EB
Chequerfield Close
Castleford
WF10 5NY
Church Feild
Fawley
Henley-On-Thames
Oxfordshire
RG9 6HZ
Cluain
Cullipool, Isle Of Luing
Oban
PA34 4UB
Cluin Siar
Cullipool
Isle Of Luing
Oban
PA34 4TX
Cluny House
Aberfeldy
Pethshire
PH15 2JT
Coille Dharaich
Kilmelford
PA34 4XD
Coille Dorroch
Degnish Road
Kimelford
PA34 4XD
Coireseileach Clachan Seil
Seil
Oban
PA34 4QZ
Coireseileach
Clachan Seil
Oban
PA34 4QZ
26/08/2011
O
26/08/2011
O
03/12/2011
O
01/08/2011
O
21/07/2011
O
21/07/2011
O
03/10/2011
O
18/07/2011
O
02/09/2011
O
03/08/2011
O
03/08/2011
O
03/08/2011
O
25/07/2011
O
30/07/2011
O
27/07/2011
O
20/07/2011
O
Page 124
Mrs Linda Battison
Mrs Maureen N Jackson
Miss Sue Sayer
F E Bisp
J Bisp
Mrs Dorothy Henderson
Mr Stephen Whitley
Alistair McIntyre
Mrs Ellen-Ann Novak
Mrs Sandra Boardman
Claire Grierson
Isla Grierson
Dr Louise Reid
Christina M Wills
Dr Kerry Caldock
Harry T Powell
Cologin
Lerags Glen
Oban
PA34 4Se
Cooraddie
Colintraive
Argyll
PA22 3AT
Copperleaf Cottage
Phillack Hill, Phillack
Hayle
TR27 5AD
Coquet Lodge
Balvicar
By Oban
Argyll
PA34 4TF
Coquet Lodge
Balvicar
By Oban
Argyll
PA34 4TF
Corrish
84 Bullwood Road
Dunoon
Argyll
PA23 7QL
Corrymoor Farm
Stockland
Honiton
EX14 9DY
Craggan
Shore Road
Garelochhead
Helensburgh
G84 0EJ
Craig Breck Farm
North Kessock
By Inverness
IV1 3XG
Craigroyston
Dalmally
PA33 1AA
Creag Dubhan
Connel
By Oban
PA37 1PF
Creag Dubhan
Connel
Oban
Argyll
PA37 1PF
Cruach Scarba
Clachan Seil
Oban
Argyll
PA34 4TL
Cuan Ard
Cuan Ferry
Isle Of Seil
Oban
Argyll
PA34 4RB
Culzean
Rockfield Road
Oban
PA 34 5 DH
Cumbrae
Grosvenor Crescent
20/07/2011
O
01/08/2011
O
17/07/2011
O
04/08/2011
O
04/08/2011
O
01/08/2011
O
21/07/2011
O
18/08/2011
O
21/07/2011
O
21/07/2011
O
03/08/2011
O
03/08/2011
O
01/08/2011
O
03/08/2011
O
18/07/2011
O
04/08/2011
O
Page 125
Mrs. Elly Post
Mr Post
Daniel Smith
Marie Smith
Mr Andrew Blair-Smith
Mrs Shelley Newton-Carter
Cath And Eric Strachan
R J MacKay
Miss Emma Ainsley
Mrs Jean Ainsley
Mr David Ainsley
Mr Donald Rice
Tim Goodwin
D And W P Pearson
R Barrett
Dr J P Moss
Connel
Oban
Argyll
PA37 1PQ
Curieplaats 65
Rotterdam the Netherlands
3069 HA
Curieplaats 65
Rotterdam
3069 HA
Dale House
The Green
Whiston
South Yorkshire
S60 4JD
Dale House
The Green
Whiston
South Yorkshire
S60 4JD
Dalmore House
Knipoch
By Oban
PA34 4QT
Dalvey
Blairgowrie
PH10 7PZ
Dargo
Achaleven Road
Connel
Argyll
Dunara
Connel
Argyll
PA37 1PH
Dunaverty
Easdale
by Oban
PA34 4RF
Dunaverty
Easdale
By Oban
PA34 4RF
Dunaverty
Easdale
Oban
PA34 4RF
Dundonnell House
Dundonnell
IV23 2QW
Dunfillan
Cuan Ferry
Seil
Oban
PA34 4RS
Dunvegan
Cnoc A' Challtuinn
Clachan Seil
Isle Of Seil
Oban
Argyll And Bute
PA34 4TR
Eaj Mhor
Clachan Seil
By Oban
PA34 4TR
Ealachan Bhana
Clachan Seil
Oban
02/08/2011
O
18/07/2011
O
12/09/2011
O
12/09/2011
O
26/07/2011
O
21/07/2011
O
03/08/2011
O
08/08/2011
O
31/07/2011
O
31/07/2011
O
16/07/2011
O
03/08/2011
O
25/07/2011
O
26/07/2011
O
01/08/2011
O
02/08/2011
O
Page 126
K L Barrett And Roger E Barrett
Mrs Sheila Potts
Mr Orlando Pritchard-Barrett
Mr Michael Heseltine
Stephen Adam
F Macrae
Dr Rolf Johannessen
MR Steven Proudfoot
R M Chipchase
David Fraser
Mrs Diane Scaife
Anne Hughes
N Robertson
C J Hughes
Mr Richard Downes
Mr Glynn Brook
Dr George Hannah
PA34 4TL
Eas Mhor
Cnoc - A - Chaltuinn Road
Clachan Seil
Isle Of Seil
By Oban
PA34 4TR
East Coilleard
Appin
PA38 4BA
Easter Campsie Farm
Glenalmond
Ph13RX
Easter Campsie Farmhouse
Glenalmond
Perth
PH1 3RX
Eastwood
Donaldson's Brae
Kilcreggan
G84 0JB
EH47 7EZ
Elleray, Shore Road
Kilcreggan
Helensburgh
G84 0HG
Elmer
Landscove
Newton Abbot
TQ13 7LZ
Fascadale
Dalriach Road
Oban
Argyll
PA34 5EQ
Fasgadh
Clachan Seil
Argyll
PA34 4TJ
Fearnach House
Kilmelford
Oban
PA34 4XD
Fearnoch
South Cuan
OBAN
Argyll
PA34 4TU
Ferniehirst
Ganavan Road
Oban
Argyll And Bute
PA34 5TU
Ferry House
South Cuan
Luing
Oban
Argyll
PA34 4TU
Fieldgarth
Birthwaite Road
Windermere
LA231BF
Fingland Farm Cottage
Wigton
CA7 5EN
Finlaggan
Clachan Seil
Oban
01/08/2011
O
23/07/2011
O
20/07/2011
O
18/07/2011
O
01/08/2011
03/08/2011
O
O
23/07/2011
O
22/07/2011
O
08/08/2011
O
01/08/2011
O
24/07/2011
O
13/09/2011
O
26/07/2011
O
16/09/2011
O
18/07/2011
O
22/07/2011
O
02/08/2011
O
Page 127
PA34 4TL
Mrs Julia Hannah
Alison Godden
Fatima Ferrer
Mr Max MacLeod
Mr Nigel Schofield
Marina Johnston
Andrew Bush
Mr Richard Yeomans
Jordan Ellison
Mr Nathan Molyneaux
Sylvia And David Willis
Edna Whyte
Mrs Astrid Van Der Kraan
Mr Stephen McLaughlin
Mrs Louisa Leader
Mr Hugh Whittle
Finlaggan
Cachan Seil
Oban
PA34 4TL
Flat 1 Courtyard Mews
105 Boulton Lane
Alvaston
Derby
DE24 0FF
Flat 1/2
54 Larchfield Avenue
Glasgow
G4 9YH
Flat 1-1
23 Polwarth Street
Glasgow
G12 9UD
Flat 16 Holyrood Court
Prestwich
Manchester
M25 1PG
Flat 2/1
4 Denby Street
Glasgow
G3 7TJ
Flat 2/2
764 Pollockshaws Road
Glasgow
G41 2AE
Flat 4
9 Shirecliffe Lane
Sheffield
S3 9AD
Flat 44
Rottrill Gardens
Marron Place
London
E8 1NG
Flat 7 Velocity West
5 City Walk
Leeds
LS11 9BG
Fulmar
4 Meikle Aiden Brae
Kilcreggan
Helensburgh
Argyll And Bute
G84 0JD
Gallery House
Cullipool
Isle Of Luing
Oban Argyll
PA34 4TX
Glenbeg
Kilmelford
PA34 4XA
Glencairn
Leithen Road
Innerleithen
EH44 6NJ
Glencarse House
Perth
PH2 7LF
Glenfeochan House
Kilmore
PA34 4QR
02/08/2011
O
16/09/2011
O
16/08/2011
O
06/08/2011
O
24/07/2011
O
16/08/2011
O
03/08/2011
O
22/07/2011
O
01/09/2011
O
18/07/2011
O
02/08/2011
O
03/08/2011
O
31/07/2011
O
18/07/2011
O
24/07/2011
O
22/08/2011
O
Page 128
Mr TJB Sinclair
Mrs Pamela Forsyth
Mr and Mrs D & J Morgan
Mr David Martin
P Morris
C A Steninger
Miss L Monk
Mr Martin Whitmore
Mrs Rosalind Whitelaw
Mrs Edith Anderson
Mrs Sofie Van Veen
N S Hunt
Mr Kevin O'Farrell
Anne Sophie Schipper
Ralph Kempers
Frances Arnold
Mr David Nattrass
Ms G Jones
Glenshellach
Cnoc A' Challtuinn
Clachan Seil
Isle Of Seil
Oban
Argyll And Bute
PA34 4TR
Glenview
Wyndham Road
Innellan
PA23 7SH
God's House Farm
Harts Lane, Ardleigh
Colchester
CO7 7QQ
Green Acre
Halterworth Lane
Romsey
SO51 9AD
Green Farm
Blackberry Lane
Coventry
CV2 3JS
Green Farm
Blackberry Lane
Coventry
CV2 3JS
Greenfield Court
Balfron
G63 0QG
Grianan
South Cuan
Isle of Luing
PA34 4TU
Grieves Cottage
Whitfield
West Linton
EH46 7AX
Guisachan House Alma Road
Fort William
PH33 6HA
Harderwijkerweg 167
Nunspeet
8071 EP
Heather Cottage
Dove Street
Ellastone
Ashbourne
Derbyshire
DE6 2GY
Heir Island
Heir Island
Skibbereen
1234567
Hellendoorn
The Netherlands
Hellendoorn
The Netherlands
Heugh CLose
Stamfordham
Northumberland
NE18 0NH
High Street House
Morland
Penrith
CA10 3AS
Hill of Bandodle
Inverurie
AB51 7NN
26/07/2011
O
07/09/2011
O
04/08/2011
O
07/09/2011
O
16/08/2011
O
16/08/2011
O
18/07/2011
O
05/08/2011
O
17/07/2011
O
02/08/2011
O
18/07/2011
O
11/10/2011
O
09/09/2011
O
22/08/2011
O
22/08/2011
O
12/09/2011
O
18/07/2011
O
26/07/2011
O
Page 129
Mr. Eddie Palmer
Mr Chas Warren
Tiery Somer
Mrs Sue Fenton
Mr Paul Dix
Mrs A Van Beckhoven
Mr Luke Alexander
M Breslin
Irene Breslin
James And Else Mellor
F Thiller
Mr George Houston
Drs Walter Vendel
Robert Batten
Mr Ian Tegner
Mr Ian Tegner
Hillhead Farmhouse
North Mains of KInnettles
Forfar
Angus
Holly Cottage
Stanton upon Hine Heath
Shrewsbury
SY4 4LW
Hollytree Cottage
Toberonochy
Isle Of Luing
Oban
Argyll
PA34 4UG
House Plot At The Anchorage
Whinbank
Clachan Seil
PA34 4TW
In der Ebene 11
Gerbrunn
D-97218
Indigoblauw
4
Zoetermeer
2718jz
Inn at Ardgour
Ardgour
Fort William
PH33 7AA
Innish
Clachan Seil
Oban
Argyll
PA34 4QZ
Innish
Clachan Seil
Oban
PA34 4QZ
Innishail
Clachan Seil
Isle Of Seil
By Oban
PA34 4TJ
Inshaig House
Isle Of Seil
Argyll
PA34 4RF
Iolair Mhara
Acha, Balvicar
OBAN
PA34 4RJ
Kamperweg 167
Wapenveld
8191 KC
Keepeers Cottage
South Cuan
Isle Of Luing
Oban
PA34 4TU
Keepers Cottage
Kilninver
Oban
PA34 4UT
Keepers Cottage
Kilninver
Oban
Argyll And Bute
PA34 4UT
10/09/2011
O
03/08/2011
O
19/08/2011
O
05/08/2011
O
17/07/2011
O
18/07/2011
O
20/07/2011
O
02/08/2011
O
02/08/2011
O
01/08/2011
O
26/08/2011
O
27/07/2011
O
18/07/2011
O
03/08/2011
O
16/08/2011
O
21/02/2013
O
Page 130
F Batten
Donald N McVean
Mr Thomas Herion
The Hon. Michael Shaw
Dr Angus McCoss
T L Nelson
Alexandra Nicholson
Rebecca Nicholson
Mr Ewan Kennedy
Mr Ewan Kennedy
Mr. Donald Hutchison
Dr Ian Collins
Ms Joanne Porter
Mrs Maggie Cole
Miss Elina Soininen
Mr. R. Doffer
Mrs Jennie Stoop
Mrs Claire Wood
Mr Thomas Eeles
Keepers Cottage
South Cuan
Oban
PA34 4TU
Kennels Cottage
Eredine
Dalmally
Argyll
PA33 1BP
Kermelberg 25
Herdecke
D-58313
Kilbrandon House Balvicar
Oban
PA34 4RA
Kilbrandon House
Balvicar
Isle Of Seil
Oban
Argyll And Bute
PA34 4RA
Kilmaronaig
Connel
PA37 1PW
Kilninver House
Kilninver
Argyll
PA34 4UT
Kilninver House
Kilninver
Argyll
PA34 4UT
Kinloch
Degnish Road
Kilmelford
PA34 4XD
Kinloch
Degnish Road
Kilmelford
PA34 4XD
Kinlochlaich House,
Appin,
PA38 4BD
Kirkhill
Kippen
FK8 3DY
Kirkliston
Edinburgh
EH29 9AD
Knowehead Cottage
Hightae
Lockerbie
DG1 1JL
Kokkakatu 4 A 16
Turku
20810
Koningsspil 16
Wieringerwaard, The Netherlands
1766 KV
Kruizemunthof 6
Barendrecht
2991HG
La Linnhette
Corpach
Fort William
PH33 7NL
Little Mill Cottage
Great Ashfield
Bury St Edmunds IP31 3HJ
03/08/2011
O
01/08/2011
O
16/04/2012
O
28/07/2011
O
21/02/2013
O
22/08/2011
O
07/09/2011
O
07/09/2011
O
25/07/2011
O
22/07/2011
O
22/07/2011
O
27/07/2011
O
26/07/2011
O
18/07/2011
O
04/08/2011
O
23/07/2011
O
30/07/2011
O
21/07/2011
O
23/08/2011
O
Page 131
Mrs Shirley Dalziel
Miss Jan Roylance
R M Tapply
Mr Daniel McArthur
Mrs Elaine Heseltine Carp
Mr W Taylor
Mr Andrew Whitley
Mr Ludwig Muendlein
Mrs Annette Elgert
Mr T Horrocks
Leonard V McGeoch
Bruce Clayton
Mrs Jane Brooke
Geoff Bisp
Gillian Bisp
Miss Cara Naden
Norman Bissell
Little Rahane Farm
Rahane
Helensburgh
G840QW
Llidsey Road
Chichester
PO20 3SU
Loch Caol Cottage
Bunessan
Isle Of Mull
Argyll And Bute
PA67 6DX
Long House
Cockermouth
CA13 9TG
Lower Leigh Farm, TokesLane
East Knoyle
SP3 6EY
Lynn Dee
Ganavan Road
Oban
PA34 5TU
Macbiehill Farmhouse
Lamancha
West Linton
EH46 7AZ
Maingasse 10
Sommerhausen
D-97286
Maingasse 10
Sommerhausen
D-97286
Market Hill
Georgemas
Halkirk
KW12 6UU
Master Mariner Rtd
Cluain Siar
Cullipool
Isle Of Luing
PA34 4TX
Merrick Cottage
Main Street
Forest Hill
Oxon
OX33 1DZ
Merricks Farm
Langport
TA10 0NF
Millpark House
Soroba Road
Oban
Argyll And Bute
PA34 4JF
Millpark House
Soroba Road
Oban
Argyll And Bute
PA34 4JF
Millview
Thorney
Langport
TA10 0DR
Mo Dhochaidh
51 Cullipool
Isle Of Luing
Oban
Argyll
PA34 4UB
22/07/2011
O
23/07/2011
O
26/07/2011
O
17/07/2011
O
18/07/2011
O
26/07/2011
O
18/07/2011
O
17/07/2011
O
17/07/2011
O
23/07/2011
O
03/08/2011
O
03/08/2011
O
20/07/2011
O
02/08/2011
O
03/08/2011
O
21/07/2011
O
03/08/2011
O
Page 132
Dr Stephen Dury
Dr Marlene Buchy
Mr Keith Mac Lean
Elizabeth C Lyons
Mr Grant Wastle
Nic Mim
C Smith
A Henderson
Anna Beckett
Barbara Smith
Catherin Macrae
Colina MacInnes
D Windsor
Dr C J Stevens
Etonella Christlieb Ouwehand
Glen Mackie
Harry Maskell
J Davies
J Dickman
Jean Wolfe
Keith Rogers
M E Sandilands
Monica Haynes
N Windsor
Name Illegible
P E Millward
Rosie And LJ And M And S Nichols
Tom Masket
Zora King
Alistair Henderson
R Henderson
Sarah F G Henderson
Andrew And Susan Durley
Mr Barry Deakin
Moorfield House
The Hill
Langport
TA10 9PU
Moorfield House
The Hill
langport
Ta109PU
Morvargh
Isle of Seil
Oban
PA34 4TJ
Morven
Cullipool
Isle Of Luing
Oban
PA34 4TX
Nettlebush
Drumelzier Place
Broughton
ML12 6JD
No 8 Tinto Place
Edinburgh
EH6 5FJ
No Address
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
No Address Given
Old Clachan Farmhouse
Clachan Seil
By Oban
PA34 4RH
Old Clachan Farmhouse
Clachan Seil
By Oban
PA34 4RH
Old Clachan Farmhouse
Clachan Seil
By Oban
PA34 4RH
Olrig
Clachan Seil
By Oban
Argyll
PA34 4TL
Overtheway
Godshill
Fordingbridge SP6 2JX
18/07/2011
O
19/07/2011
O
18/07/2011
O
03/08/2011
O
18/07/2011
O
03/08/2011
03/08/2011
02/08/2011
21/08/2011
01/08/2011
18/08/2011
01/08/2011
14/11/2011
30/09/2011
25/07/2011
18/08/2011
02/09/2011
02/08/2011
02/08/2011
02/08/2011
03/08/2011
01/08/2011
02/08/2011
14/11/2011
04/08/2011
02/08/2011
05/08/2011
02/09/2011
04/08/2011
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
02/08/2011
O
02/08/2011
O
02/08/2011
O
03/08/2011
O
01/09/2011
O
Page 133
Mr Robin Harvey
Miss G J Williams
Mr Duncan Monteith-Hodge
Cynthia Kirpins
Sebastiaan Koperberg
Master Dylan Inglis
Mr James Inglis
Mr Christopher Liversedge
Mrs Karen Liversedge
H Blakeney
Mr David Bridge
Mrs Mary Barnes
Mrs Marion Brown
Mr Alexander Smart
Mrs B Boston
Mr Roger Wright
Mrs Samantha Jarvis
Mr Paul Knight
Penwith
Ceum Dhun Righ
Benderloch
PA37 1ST
Pintalia
Appin
Argyll And Bute
PA38 4BA
Pole Position Internet Services Ltd
4 George Street
Oban
Argyll
Prins Bernhardlaan 146M
2032 ZE Haarlem
The Netherlands
Prinsbernhardlaan 146M
2032 ZE Haarlem
Netherlands
Raera Farm
Kilninver
Oban
PA34 4UT
Raera Farm
Kiilninver
Oban
PA34 4UT
Ravenswood
Kilmelford
PA34 4XD
Ravenswood
Kilmelford
PA34 4XD
Reay Cottage
Clachan Seil
By Oban
PA34 4TL
Redesdale House
Skipness
Tarbert
PA29 6YG
Rhumore
Drimnin
By Oban
Argyll
PA80 5XZ
River Vale 24 Drummie Road
Devonside
Tillicoultry
FK13 6HT
Riverdale, Barran
Kilmore
Oban
PA34 4XR
Rose Cottage
Apeton
Church Eaton, Stafford
ST20 0AE
Rudha Croise
Loch Eck
Dunoon
PA23 8SG
Rye Green
Rye
Puriton
TA7 8BZ
Salmon & Trout Association
Fishmongers' Hall
London
EC4R 9EL
02/08/2011
O
26/07/2011
O
18/07/2011
O
03/08/2011
O
03/08/2011
O
31/08/2011
O
17/08/2011
O
31/10/2011
O
30/10/2011
O
02/08/2011
O
19/07/2011
O
26/07/2011
O
18/07/2011
O
20/07/2011
O
26/07/2011
O
21/07/2011
O
18/07/2011
O
18/07/2011
O
Page 134
Mrs Elizabeth Ustic
Dr Kevin Butt
Mr Andrew Ottaway
Mrs Elizabeth Evans
Ms Jools Bond
Mike Barlow
Mrs Christine Ferrie
Mr Barry Johnson
Mr Richard Ellis
Mr Christopher Bromley
Mr Jeffrey Banks
Mr Gordon Rothero
Mr Anthony Hammock
Mrs Olga Hammock
Mr Michael Barlow
Mr. Jack Tempel
Mrs. Lilian Verheijen
Mrs. Christine Metcalfe
School House
Lillingstone Dayrell
Buckingham
MK18 5AP
School of Built and Natural Environment
Preston
PR1 2HE
Seal Protection Action Group
PO Box 2673
Lewes
BN8 5BZ
Shore Cottage
Pirnmill
Isle of Arran
KA27 8HP
South Allington House
South Allington
Kingsbridge
TQ7 2NB
South Cuan
Isle Of Luing
PA34 4TU
Stanton Villa
Camus na ha
Fort william
ph33 7nn
Stonechat
Mill Lane, Well
Bedale
DL82RX
Stoneleigh
Thong Lane
Netherthong, Holmfirth
HD9 3EE
Stranraer
Carlidnack Lane
Falmouth
TR11 5HE
Strathview Station Road
Abernethy
Perth
PH2 9JS
Stronlonag
Glenmassan
Dunoon
PA23 8RA
Strumhor
Connel
Oban
PA37 1PJ
Strumhor
Connel
Oban
PA37 1PJ
Sunnybrae
South Cuan, Isle of Luing
Oban
PA34 4TU
Swarte Liester 16
Hippolytushoef, the Netheralnds
1777 DT
Swarte Liester 16
Hippolytushoef, the Netheralnds
1777 DT
Taigh a Luana
Loch Avich
Taynuilt
PA35 1HJ
18/07/2011
O
18/07/2011
O
25/07/2011
O
18/07/2011
O
28/07/2011
O
03/08/2011
O
21/07/2011
O
18/11/2011
O
18/07/2011
O
07/09/2011
O
11/09/2011
O
22/07/2011
O
20/07/2011
O
17/07/2011
O
18/07/2011
O
18/07/2011
O
18/07/2011
O
10/08/2011
O
Page 135
Mrs Caroline Dingwall
Ms Carol Williams
Mrs Phylis Malcolm
Mr Kenneth Campbell
Mr C D Rose
Name Illegible
Mr Nick Barberton
Mr Pol Berguis
Erin Inglis
Jemma Inglis
Justin Brooks
Ms Syann Van Niftrik
Dr Jennifer Joy
Mr James Robertson
Mr Alasdair Steele
Tail Farm
Fowlis Wester
Perth
PH7 3NL
Tancrey
Crieff
PH7 4EA
Tapsalteerie Cottage
Cullipool
Isle Of Luing
PA34 4UB
The Bank House
10 Main Street
Doune
FK16 6BJ
The Bothy Achnaclach
Clachan Seil
Isle Of Seil
Oban
Argyll And Bute
PA34 4TL
The Coach House
Ardmaddy
By Oban
Argyll
PA34 4QY
The Cottage
woodgreen
fordingbridge
SP62AR
The Cottage
Forteviot
Perth
PH2 9BT
The Cottage
Raera Farm
Kilninver
Oban
Argyll
PA34 4UT
The Cottage
Raera Farm
Kilninver
Oban
Argyll
PA34 4UT
The Cottage
Raera Farm
Kilninver
Oban
Argyll
PA34 4UT
The Cottage
Woodgreen
Fordingbridge
Hants
The Croft
Off Haygate Road
Wellington, Telford
TF1 2BW
The Four Hollies
Barrack Road
Comrie
PH6 2EQ
The Haven
Clachan Seil
Seil Island
PA34 4TN
21/07/2011
O
06/09/2011
O
04/08/2011
O
01/08/2011
O
26/07/2011
O
04/08/2011
O
26/07/2011
O
28/07/2011
O
10/10/2011
O
05/09/2011
O
05/09/2011
O
22/07/2011
O
08/08/2011
O
25/07/2011
O
20/07/2011
O
Page 136
Douglas Curley
Mr Allan Eunson
Alan Morton
Heather Morton
Prof. Hugo Lentmann
A R Wands
Hugh Martin
Mr Simon Smith
John Jess And M M MacDonald
Mrs Judy Lawson
Mr Henry Middleton
Dr Sue Baker
Mrs Janet Perkins
Mrs Karen Renouf
Mr Bill Jackson
Lasta King
The Haven
Clachan
Seil
Oban
PA34 4TN
The Mews
Torryburn
Kintore
AB51 0XP
The Old Bakehouse
High Street
Denford
Northants
NN14 4EQ
The Old Bakehouse
High Street
Denford
Northants
NN14 4EQ
The Old Boathouse
Loch Feochan
Oban
PA34 4SF
The Old House
Clachan Seil
Oban
PA34 4TL
The Old House
Clachan Seil
Oban
PA34 4TL
The Old Manse
Dalriach Road
Oban
PA34 5JE
The Old Post Office
1 Breadalbane Terrace
Clachan Seil
PA34 4TL
The Old Rectory
Jacobstowe
Okehampton
EX20 3RQ
The Old Shop
Enford
Pewsey
SN9 6AR
The Rookery
Rookery Road
Blackmore
CM4 0LG
The Roost, Leiston Road
Middleton
Saxmundham
IP17 3NS
The Shielin
Keillour
Methven
PH1 3RA
The Smithy, Auchnasaul
The Smithy, Auchnasaul, by Clachan Seil
Oban
PA34 4RH
The Swallows
South Cuan
Oban
Argyll
PA34 4TU
01/08/2011
O
30/08/2012
O
22/08/2011
O
22/08/2011
O
30/07/2011
O
02/08/2011
O
02/08/2011
O
02/08/2011
O
02/08/2011
O
19/07/2011
O
27/08/2011
O
18/07/2011
O
02/08/2011
O
20/07/2011
O
18/07/2011
O
04/08/2011
O
Page 137
Mr Dave Blackham
Mr Teresa Watts
Mr Charles Clover
Ms Catherine Pendreigh
Mrs Cicely Gill
Mrs Valerie Bichener
John S C Taylor
Mrs Susan Harris
Mr Mark Carter
Mrs Iris Bell
Dr Kerry Schofield
Ms Valerie Shakeshaft
Mr Graham Shakeshaft
Mr Nicholas Shakeshaft
Ann Reid
Stuart Reid
E Abrol
Mr David Woodhouse
The Tea Gardens
Framilode Passage
Saul
GL2 7LF
The Tea Gardens
Framilode Passage
Saul
GL2 7LF
The Well House
High St, Dedham
Colchester
CO7 6AB
The Whins
Ferry Road
Tayinloan
Argyll PA29 6XQ
The Yellow Land
Whiting Bay
Isle of Arran
KA27 8PZ
Thornloe Guest House
Albert Road
Oban
PA34 5EJ
Tigh Innis
Balvicar Bay
Isle Of Seil
PA34 4TE
Tigh Na Bata
Kilmelford
Oban
PA34 4XA
Tigh na Mara
Bonawe
Oban
PA47 1RL
Tir Aluinn
Clachan Seil
By Oban
PA34 4TL
Tor Cottage
South Brent
TQ10 9HB
Tor View
South Brent
Devon
TQ10 9HB
Tor View
Wrangaton
South Brent
Devon
TQ10 9HB
Tor View
Wrangaton
South Brent
TQ10 9HB
Torbeag
Clachan Seil
Oban
Pa34 4TJ
Torbeag
Clachan Seil
Oban
PA34 4TJ
Torosay
Cameron Road
Fort William
PH33 6LH
Torr Buan house
ULva ferry
17/07/2011
O
17/07/2011
O
18/07/2011
O
20/07/2011
O
19/07/2011
O
21/07/2011
O
02/08/2011
O
25/10/2011
O
15/07/2011
O
03/08/2011
O
03/08/2011
O
21/07/2011
O
29/07/2011
O
22/07/2011
O
03/08/2011
O
03/08/2011
O
16/08/2011
O
17/07/2011
O
Page 138
Isle of Mull
PA73 6LY
Mr Mark Struthers
Mr And Mrs J P Colston
M Brown
Mr Mike Forsyth
Mr Antony Watkins
James Dinsmore
Mr. Kurt Bourdeaux
Mrs Carol Sturrock
Dr Alan Pickering
Mrs Susan Turner
Mr Anthony Compson
Ms Johanna Storm Rusu
Mr John Widdaker
John And Flora Anderson
Mr John Wilson
Mrs Alice Wilson
Ellie Fidler
Torsa Farmhouse
C/O Ardmaddy Castle
By Oban
PA34 4QY
Traigh Mhor
Clachan Seil
Isle Of Seil
Oban
Argyll And Bute
PA34 4TJ
Trevelyan College
Durham University
Durham
DH1 3LN
Trinity Cottage
Lempitlaw
Kelso
TD5 8BN
Tuckers Hill
Frog Lane
Langport
TA10 0NE
Tulloch Beag
Kilmelford
By Oban
Argyll
PA34 4XA
Vooruitgangsstraat 15
Harelbeke
8530
Wedgewood
Higher Heath
SY13 2HR
Wellbeck
Pump lane
Springfield, chelmsford
Cm1 6ta
Werner-Friedmann-Bogen 38
Munich
D-80993
West Street Farmhouse
Walsham le Willoows
Bury St Edmunds
IP31 3AP
Westcroft House
Hebden Bridge Road
Oxenhope, Keighley
BD22 9QJ
Westgate House
Milburn
Penrith
CA10 1TW
Westrioch
Campbeltown
Argyll
PA28 6NT
Willowburn
Clachan Seil
Oban
PA34 4TJ
Willowburn
Clachan Seil
Oban
PA34 4TJ
Woodleigh
Wood Lane
Stanmore Middlesex HA7 4JY
26/07/2011
O
26/07/2011
O
01/09/2011
O
05/09/2011
O
09/08/2011
O
27/07/2011
O
18/07/2011
O
04/08/2011
O
05/08/2011
O
02/08/2011
O
31/08/2011
O
18/07/2011
O
27/07/2011
O
03/08/2011
O
01/08/2011
O
01/08/2011
O
05/08/2011
O
Page 139
SUPPORTERS:
Mr Michael Stanford
Mr D Fowler
Mr Ian Armstrong
Miss Rosa Downing
Master Corey Choudhury- Reid
Mr Robin MacLean
Fusion Marine Ltd
Inverlussa Marine Services Ltd
11B Calton Ave
Campbeltown
PA28 6NB
22 St Clair Way
Ardrishaig
Lochgilphead
PA308FB
3 Ardconnel Villa
Rockfield Road
Oban
PA34 5DH
48 Soldierstown Road
Aghalee
Craigavon
BT 67 0ES
76 Crestway
London
SW15 5DD
Morvargh
Clachan Seil
By Oban
PA34 4TJ
The Marine Resource Centre
Barcaldine
By Oban
Argyll
Scotland
PA37 1SE
Craignure
Isle of Mull
PA65 6BD
20/02/2013
S
14/12/2011
S
23/01/2013
S
31/07/2011
S
03/09/2011
S
28/07/2011
S
11/02/2013
S
06/03/13
S
22/07/2011
R
23/07/2011
R
OTHER REPRESENTATIONS:
Mr Glenn King
Mr Joe Kerr
1 St Marys Close
Offton
Ipswich
IP8 4RZ
West Bank House
West Bank Road
Ardrishaig
PA30 8HB
Page 140
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Page 141
APPENDIX B TO APPLICATION 11/01066/MFF
HABITATS REGULATION APPRAISAL – ARGYLL AND BUTE COUNCIL
Date
February 2013
Development proposal
Relocation of Ardmaddy salmon farm in Seil Sound
Natura site(s)
Firth of Lorn Special Area of Conservation
A. INTRODUCTION
This document is a record of the full Habitats Regulation Appraisal, undertaken by Argyll and Bute Council in
respect of the above development proposal to assess the implications on the Firth of Lorn Special Area of
Conservation.
Planning authorities are advised by Scottish Government not to duplicate the regulatory roles of other
regulatory bodies. Had a CAR licence been granted for this development prior to a planning application being
submitted, Argyll and Bute Council would not have considered the potential environmental impacts covered by
SEPA’s CAR process and SNH would not have advised that an Appropriate Assessment would have been
required. Therefore the Council is only undertaking an Appropriate Assessment for this application as the
planning process had started prior to the determination of the CAR licence by SEPA.
The focus of the Appropriate Assessment below (see Section 6) is identical to that undertaken by SEPA in their
determination of the CAR licence for this application, and relates to aspects of the development proposal which
are controlled by SEPA through the CAR licence process. Therefore, the Council have based the assessment
and overall conclusions on SEPA’s Appropriate Assessment which is attached as Annex 1.
B. PROJECT AND SITE DESCRIPTION
1
Brief description of the project
The development proposal is to relocate the existing Ardmaddy salmon farm site approximately 900m
south within Seil Sound and to increase the maximum licensed biomass from 1300 to 2500 tonnes. In
line with an increase in biomass the applicant has applied to SEPA for an increase in the amount of sea
lice treatment chemicals that can be discharged. If granted the existing Ardmaddy site will be
relinquished.
SEPA have granted a CAR licence for the proposed site for the maximum biomass of 2500 tonnes and an
increase in the amount of sea lice treatment chemicals. This CAR licence was granted following the
completion of an appropriate assessment, which concluded that the proposal would not have an adverse
impact on site integrity of the Firth of Lorn SAC.
2
Relevant natura site(s)
The proposed development is not situated within any European marine sites but is sited approximately
1.8km to the east of the Firth of Lorn Special Area of Conservation.
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3
Qualifying interests for the natura site and conservation objectives for each interest
Qualifying interests
(see http://jncc.defra.gov.uk/ProtectedSites/SACselection/sac.asp?EUCode=UK0030041)
The natural heritage interests of the Firth of Lorn SAC for which the site is designated are:
Annex I habitats that are a primary reason for selection of this site:
• 1170 Reefs
This well-defined, discrete area encompasses a complex group of islands, sounds and inlets
characterised by some of the strongest tidal streams in the UK. The area is moderately exposed to
wave action with very sheltered pockets enclosed by islands and skerries. Reefs extend from the
shallow depths between the islands and mainland into depths of over 200m, in many places close
inshore. The varied physical environment is reflected in the variety of reef types and associated
communities and species, which are amongst the most diverse in both the UK and Europe. These
range from those characteristic of conditions sheltered from waves and currents, to those influenced
by extreme tidal streams. A rapid transition in communities occurs with the deceleration of the tidal
streams. Species present include some which are normally characteristic of deeper water (the
sponges Mycale lingua and Clathria barleii, and the featherstar Leptometra celtica), and others which
are considered scarce (including the brown alga Desmarestia dresnayi). Many species occurring here
have either a northern or southern-influenced distribution and reach their geographic limits in this
area, for example, the southern cup-coral Caryophyllia inornata, the nationally scarce brittlestar
Ophiopsila annulosa, and the northern bryozoans Bugula purpurotincta and Caberea ellisii.
Annex I habitats present as a qualifying feature, but not a primary reason for the selection of this site:
• Not applicable.
Annex II species that are a primary reason for the selection of this site:
• Not applicable.
Annex II species present as a qualifying feature, but not a primary reason for site selection:
• Not applicable.
Conservation Objectives
(see http://gateway.snh.gov.uk/sitelink/documentview.jsp?p_pa_code=8256&p_Doc_Type_ID=29)
To avoid deterioration of the Annex I habitats (listed above) thus ensuring that the integrity of the site is
maintained and the site makes an appropriate contribution to achieving favourable conservation status
for each of the habitats; and
To ensure for the Annex I habitats (listed above) that the following are maintained in the long term:
· extent of the habitat on site
· distribution of the habitat within site
· structure and function of the habitat
· processes supporting the habitat
· distribution of typical species of the habitat
· viability of typical species as components of the habitat
· no significant disturbance of typical species of the habitat.
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C. IS AN APPROPRIATE ASSESSMENT REQUIRED?
4
Is the proposal directly connected with, or necessary to, conservation management of the site?
No.
5
Is the proposal likely to have a significant effect on the site (either alone or in combination with other
plans or projects)?
SNH were consulted by the Council as a statutory consultee on the planning application and
Environmental Statement for this proposal. SNH advised that the proposal will have a likely significant
effect on the qualifying interest of the Firth of Lorn Special Area of Conservation (SAC) and
recommended that Argyll and Bute Council undertake an appropriate assessment for the proposal in
view of the site’s conservation objectives.
This view was based on the potential of the proposed development to affect the qualifying interest of
Firth of Lorn SAC from the deposition of organic waste and chemo-therapeutants transported into the
SAC by tidal currents.
D. APPROPRIATE ASSESSMENT
6
Scope of the Appropriate Assessment
SNH advice is that the Appropriate Assessment should be based on an appraisal of the following:
· The transport of organic waste by tidal currents from the proposed development site to it’s eventual
resting place or area of dispersal and therefore its effect on the interest of the Firth of Lorn SAC; and
· The transport of chemo-therapeutants by tidal currents from the proposed development site to their
eventual resting place and therefore a resulting effect on the interest of the Firth of Lorn SAC.
The AA should be undertaken in view of the site’s conservation objectives as listed in Part C above.
It is the view of Argyll and Bute Council that the Appropriate Assessment should focus only on the
qualifying features of the Firth of Lorn SAC, in this case ‘reef’ habitat, and not on other habitats and
species listed under Annex I and II of the Habitats Directive which are not qualifying features of the SAC.
This view is in line with SNH’s interpretation of the Habitats Directive.
As the development proposal is out with the Firth of Lorn SAC, potential physical disturbance of
qualifying reef habitat from cage anchors and moorings is not relevant and is therefore not considered
further.
7
Elements of development proposal relevant to the scope of the Appropriate Assessment
The following elements of the development proposal are considered relevant to the scope of the AA:
• relocation of site in Seil Sound from Ardmaddy, approximately 900m south, to Ardmaddy South;
• change in the amounts of in-feed and bath sea lice treatments; and
• increased biomass from 1300t to 2500t.
The potential hazards of the development upon the qualifying reef interest are likely to be individually or
in combination: (a) smothering, (b) chemical treatments, and (c) cumulative nutrient enhancement.
These pressures will be controlled through the CAR licence already granted by SEPA (CAR/L/1099909).
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8
SAC features in the vicinity of the proposal
Both the proposed and existing site are outwith the SAC boundary, however, the proposed site is
approximately 300m closer to the nearest part of the SAC boundary at Cuan Sound. The existing site is
2.1km away and the proposed site 1.8km away from the SAC. The existing and proposed cage locations
and SAC boundary can be seen in Figure 1 below.
Figure 1. Proposed cage locations (red circles) and SAC boundary for the proposed Ardmaddy South and
existing Ardmaddy fish farm sites
Firth of Lorn SAC
Within or near (less than 3km) to the Firth of Lorn SAC there are seven licensed marine fin fish farms
producing salmon at Port nan Seannag (Lunga) (CAR/L/1000811), Ardmaddy (CAR/L1010472), Bagh
Lachlainn (CAR/L/1025495), Port na Cro (CAR/L/1000810), South West Shuna (CAR/L/1025496), Bagh Dail
nan Ceann North & South (CAR/L/1004226), and Ardifuir (CAR/L/1021927). These sites are authorised by
SEPA under the Controlled Activity Regulations (CAR) and allowed to use certain listed chemicals for such
activities as fish health, net anti-fouling and bio security.
9
Direct and indirect effects on qualifying reef habitat
As discussed in Section 6 above, this Appropriate Assessment focuses on the potential impacts of the
development proposal from:
· The transport of organic waste by tidal currents from the proposed development site to it’s eventual
resting place or area of dispersal and therefore its effect on the interest of the Firth of Lorn SAC; and
· The transport of chemo-therapeutants by tidal currents from the proposed development site to their
eventual resting place and therefore a resulting effect on the interest of the Firth of Lorn SAC.
Sensitivity of qualifying reef habitat
SEPA’s Appropriate Assessment identifies that few studies have been undertaken to evaluate the effects
4
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of different levels of solids flux on reef organisms. In terms of the CAR assessment process, the solids
flux:ITI relationship has been empirically determined specifically for benthic infauna, and therefore is not
directly applicable to reef fauna. However, it is considered likely that some reef fauna will be more
sensitive to solids flux.
SEPA’s Appropriate Assessment (see Annex 1 - Section 5 ‘Effects on reef species’) identifies relevant reef
organisms to which AMBI (AZTI Marine Biotic Index) scores have been assigned. The taxa noted from the
SAC in the site description (see Section3 above) with AMBI scores assigned, e.g. Dendrodoa grossularia,
Corynactis viridis, Caryophylla inornata, Ophiopsila annulosa, all fall into group I of the AMBI scores,
identified as species very sensitive to organic enrichment and present under unpolluted conditions.
The MarLIN website www.marlin.ac.uk has assessed available information on the sensitivity of different
species and habitats to various anthropogenic factors. Relevant to this assessment are the factors –
‘smothering’; ‘increase in suspended sediment’; ‘synthetic compound contamination’; ‘hydrocarbon
contamination’; and ‘changes in nutrient levels’. For those species listed in the qualifying interests, no
information is available or they are not listed.
Information is however available for the following four types of reef habitat (biotopes) which are likely to
be found in the SAC, and is presented in Table 1:
· Antedon spp., solitary ascidians and fine hydroids on sheltered circalittoral rock (Biotope CR.LCR.BrAs.AntAsH) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=313&code=2004
· Neocrania anomala and Protanthea simplex on very sheltered circalittoral rock (Biotope CR.LCR.BrAs.NeoPro) http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=5&code=2004
· Ophiothrix fragilis and/or Ophiocomina nigra beds on slightly tide-swept circalittoral rock or mixed
substrata (Biotope - CR.MCR.EcCr.CarSp.Bri)
http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=278&code=2004
· Faunal and algal crusts, Echinus esculentus, sparse Alcyonium digitatum and grazing-tolerant fauna
on
moderately
exposed
circalittoral
rock
(Biotope
CR.MCR.EcCr.FaAlCr.Pom)
http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=337&code=2004.
Table 1. MarLIN sensitivity information
Assessment details
Sensitivity information
Smothering
The biotopes have been
assessed
against
smothering by 5cm of
sediment for one month.
Suspended
sediment
The
biotopes
were
assessed against 100mg/l
for one month.
Synthetic
compounds &
hydrocarbon
contamination
For synthetic compounds
and
hydrocarbon
contamination,
the
biotopes were assessed
against mass mortality
(both short- and longterm), a reduction in
MarLIN
indicates
that
the
biotopes
CR.LCR.BrAs.AntAsH,
CR.LCR.BrAs.NeoPro
and
CR.MCR.EcCr.CarSp.Bri will have a moderate sensitivity
to smothering, due to their high intolerance but
moderate
recoverability.
The
habitat
CR.MCR.EcCr.FaAlCr.Pom has an intermediate
intolerance to smothering, but a low sensitivity due to
its high recoverability.
MarLIN indicates that the above biotopes are not
sensitive or have a very low sensitivity to an increase
in suspended sediment. This is due to their low
intolerance and either immediate or very high
recoverability.
MarLIN
indicates
that
the
biotopes
CR.LCR.BrAs.AntAsH and CR.MCR.EcCr.FaAlCr.Pom
have a moderate sensitivity to synthetic compound
contamination, due to a high intolerance but high
recoverability. There is insufficient information for the
CR.LCR.BrAs.NeoPro
and
biotopes
CR.MCR.EcCr.CarSp.Bri, however they are also
5
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abundances, and sub-lethal expected to show a moderate sensitivity, high
effects such as a reduced intolerance and high recoverability.
reproductive potential.
For hydrocarbon contamination, MarLIN indicates the
biotope CR.LCR.BrAs.AntAsH will have a moderate
sensitivity, due to a high intolerance but high
recoverability. There is insufficient information for the
biotope CR.LCR.BrAs.NeoPro, but this is expected to
show a similar response to CR.LCR.BrAs.AntAsH. The
biotopes
R.MCR.EcCr.CarSp.Bri
and
CR.MCR.EcCr.FaAlCr.Pom are both listed as having a
low sensitivity, due to their low or intermediate
intolerance and high recoverability.
Changes
in
For changes in nutrient levels, MarLIN indicates the
nutrient levels
biotopes CR.LCR.BrAs.AntAsH, CR.LCR.BrAs.NeoPro
and CR.MCR.EcCr.CarSp.Bri will have a low sensitivity
or are not sensitive, due to a high recoverability and
low intolerance. The biotope CR.MCR.EcCr.FaAlCr.Pom
will have a moderate sensitivity, due to a high
intolerance but high recoverability.
Assessment of effects from solid waste
The deposition of waste feed and faecal particles has the potential to smother reef habitat and
associated species. SEPA uses the bespoke particle-tracking model AutoDepomod to determine the sea
bed deposition footprint of particles leaving the cages and also any re-suspension of deposited material
to the wider area.
SEPAs Appropriate Assessment has provided a detailed assessment of the impacts from the likely
deposition of solids waste within the Firth of Lorn SAC, in relation to qualifying reef habitat. This
assessment has been based on the detailed modelling and information considered during their
consideration of the CAR licence.
Argyll and Bute Council have reviewed SEPA’s assessment on ‘Solid Flux Impact’ (see Appendix 1 –
Section 5) and agree with the summary conclusions set out below.
Summary of solids flux impacts
The proposed changes in solids flux may give rise to a likely significant effect. This likely significant effect
is due to the predicted export of solids emanating from the proposed fish farm being transported into the
Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary (2%).
However, the above assessment leads to the conclusion that the proposal will result in a relatively small
(<3%) increase of solids from fish farms in the general area of the SAC. The reported natural
sedimentation rates in the SAC are relatively high, and the increase in sedimentation in the SAC, resulting
from the proposal, represents 0.00001% of the natural background rates.
The levels of smothering and sedimentation are negligible compared with those used for the MarLIN
sensitivity assessments for relevant reef habitats, and the increase in solids flux over the background
levels would not be effectively measurable. This combined with the generally dispersive nature of the SAC
and beyond, means it is reasonable to conclude that the proposed changes in solids flux will not give rise
to a likely significant effect on the SAC designated features.
This means it is reasonable to conclude that any potential impacts due to changes in solids flux on the SAC
designated features will be negligible and will not compromise the site’s Conservation Objectives. This
conclusion is based upon the most up-to-date scientific research, and best available rigorous modelling.
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Assessment of effects from chemical treatments
Sea lice medicine residues, both in the water column and in the sediment, have the potential to be toxic
to reef habitat and associated species. The principal materials that may affect sea bed fauna are the sea
lice bath treatments azamethiphos, cypermethrin and deltamethrin and the in-feed treatments
emamectin benzoate and teflubenzuron. These products are licensed by SEPA for use against sea lice
infestations on salmon farms.
SEPAs Appropriate Assessment has provided a detailed assessment of the impacts from the likely
transport of chemotheraputents into the Firth of Lorn SAC, in relation to qualifying reef habitat. This
assessment has been based on the detailed modelling and information considered during their
consideration of the CAR licence.
Argyll and Bute Council have reviewed SEPA’s assessment on ‘Toxic effects from sea lice treatments’ (see
Appendix 1 – Section 5) and agree with SEPAs summary conclusions set out below.
Summary of sea lice treatment impacts
The proposed changes in the use of licensed sea lice treatments may give rise to a likely significant effect.
The MarLIN sensitivity assessments do not examine the effects of specific sea lice treatments on reefs, but
tests on the most sensitive taxa have been used to determine the Environmental Quality Standards (EQS).
For bath treatments, the likely significant effect is due to the treatment plumes dispersing from the
proposed fish farm and being transported into the Firth of Lorn SAC, mainly through the Cuan Sound.
However, the modelling indicates that the dispersal plumes are not taken directly toward the SAC, and
therefore the 0.5km2 mixing zone will not extend into the SAC. This means that bath treatment levels
within the SAC will all be below the Environmental Quality Standards (EQS). This combined with the
generally dispersive nature of the SAC and beyond, allows the above assessment to lead to the conclusion
that any potential impacts resulting from the proposed changes in licensed bath treatments will be
negligible and will not compromise the site’s Conservation Objectives. This conclusion is based upon the
most up-to date scientific research, and best available rigorous modelling.
For in-feed treatments, the likely significant effect is due to the predicted export of sea lice treatment
residues emanating from the proposed fish farm, being exported into the Firth of Lorn SAC, through both
the Cuan Sound (67%) and the southern boundary (2%). However, the above assessment leads to the
conclusion that the proposal will result in a very small (<1%) increase of sea lice residues. This amount is
not statistically significant (at the 1% or 5% levels), and is well within the margins of error for sampling,
analysis and the model. Furthermore, the increase in the SAC is equivalent to 0.03% of the far field
Environmental Quality Standard (EQS) of 0.763µg/kg. Such an increase is not effectively measurable, and
this combined with the generally dispersive nature of the SAC and beyond, means it is reasonable to
conclude that any potential impacts resulting from the proposed changes in licensed in-feed treatments
will be negligible and will not compromise the site’s Conservation Objectives. This conclusion is based
upon the most up-to-date scientific research, and best available rigorous modelling.
10
Cumulative effects
Solid waste
As discussed in Section 10 above, SEPAs assessment of the effects from deposition of exported solid
waste identified that:
· the increase in solids exported from the proposed Ardmaddy South site is negligible when compared
to the amounts already exported from neighbouring fish farms in the Seil Sound and Sound of Shuna
area;
· any solids exported into the SAC will be widely distributed, both within the SAC and beyond; and
· the predicted amounts of solids entering the SAC resulting from nearby fish farms are many orders of
magnitude below the natural sedimentation rates, and can thus be considered insignificant.
7
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SEPA’s Appropriate Assessment identifies that the increase in exported solids represents less than 3% of
the total solids exported from all of the fish farms within, or near to the SAC boundary and within Seil
Sound and the Sound of Shuna. This increase represents 0.00001% of the natural background
sedimentation rates which makes the predicted total sedimentation from the export of solids from all
adjacent farms, including the proposed Ardmaddy site, equivalent to less than 0.00033% of the
background sedimentation rates. The Council, therefore consider that cumulative deposition of exported
solids will be negligible and will not compromise the site’s conservation objectives.
Sea lice treatments
Bath treatments
As identified in Section 10 above, SEPA modelling indicates that the dispersal plumes for bath treatments
are not taken directly towards the SAC and therefore the 0.5km2 mixing zone will not extend into the
SAC. This means that the levels of bath treatment residues within the SAC will be below SEPA
Environmental Quality Standards and therefore not present a risk to the SAC qualifying features.
The amount of bath treatment chemicals licensed by SEPA for the proposed site is less than that which
was consented for the existing Ardmaddy site. As there is no increase in use of bath treatments it is
concluded that there can be no cumulative impact resulting from the new proposal.
In-feed treatments
The use of in-feed treatments, as licensed by SEPA for the new Ardmaddy site, will result in a very small
(<1%) increase in sea lice residues, which represents 0.03% of the far field Environmental Quality
Standard within the SAC. This increase is not statistically significant or effectively measureable and
therefore it is considered that the proposed changes in use of licensed sea lice treatments will not result
in cumulative impacts on the SAC.
Nutrient enhancement
The Scottish Government’s “Locational Guidelines for the Authorisation of Marine Fish Farms in Scottish
Waters” categorise sea lochs, voes and embayments into 3 categories based on predictions of the
impacts from the existing scale of development. Models predicting the nutrient enhancement of the
water column and the proportion of sea bed likely to be degraded are used to identify areas more likely
to be able to support additional farmed fish biomass. Currently, no further increases in maximum
biomass are permitted in Category 1 areas. Increases are more likely to be permitted in Category 2 and 3
areas (subject to site-specific assessment through EIA and CAR). Neither the Sound of Seil or Loch Shuna
have been categorised due to their complex, open nature.
In support of the planning application the applicant provided an assessment of the predicted cumulative
nutrient enhancement of the existing and proposed fish farms in Seil Sound and Loch Shuna. The Council
has reviewed this assessment and agrees with the estimated ECE value from all fish farms of 13.37µg/l.
As advised by SEPA, the estimated input from the existing and proposed farms should be assessed
against OSPAR and UKTAG reference or background levels by adding the calculated Equilibrium
Concentration Enhancement (ECE) for all farms in the water body to the reference/background level and
then the result assessed as to whether it breaches the threshold of 50% above the reference value.
Nutrient enhancement calculations according to a Equivalent Concentration Enhancement (ECE) model
are described on the Marine Science Scotland website.
The coastal waters of Seil Sound and Loch Shuna can be classified as ‘Coastal waters’ where Dissolved
Inorganic Nitrogen (DIN) normalised to a salinity of 32ppt has a reference value of 12µM (168µg/l) and a
threshold of 18µM (252µg/l). Adding the ECE value for all fish farms (13.37µg/l) to the reference value
(168µg/l) gives a value of 181.37µg/l, which is below the 252µg/l threshold.
It is therefore considered unlikely that nutrient inputs from this development in combination with other
fish farms will have a detrimental effect on water quality or upon primary productivity in Loch Shuna and
Seil Sound, in terms of nutrient enhancement.
8
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11
Enforceable conditions on CAR licence which manage the risk of environmental impact, relevant to this
Appropriate Assessment
As identified in Section 7 of SEPAs Appropriate Assessment, the CAR licence that has been granted for
this development proposal contains site-specific numeric limits for the maximum biomass and sea lice
treatments, such that the solids flux and use of sea lice treatments will not be predicted to exceed the
modelled Environmental Quality Standards (EQS). Environmental monitoring is built into the licence and
enforcement action is taken if these are exceeded.
These limits are there to protect the environment, and their thresholds are set to protect the most
sensitive fauna using a well-tried and tested process of EQS setting and additional inbuilt safety factors.
SEPA believes that the above will provide appropriate mitigation to help avoid impacts on the site’s
integrity with respect to its conservation objectives.
12
Conclusion of Appropriate Assessment
Can it be ascertained beyond reasonable scientific doubt that the proposal will not adversely affect the
integrity of the SAC/SPA?
The following text, lifted directly from SEPAs appropriate assessment (Annex 1) provides a detailed
conclusion as to whether the development proposal will affect each conservation objective for the Firth
of Lorn SAC. Given that our assessment above (Section 10) has been based on SEPA’s consideration of
the CAR licence for this proposal, Argyll and Bute Council have used these conclusions for each
conservation objective to form our overall conclusion of the Appropriate Assessment.
Distribution of the habitat within site
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
effects of sea lice medicines are not expected to affect this conservation objective.
Structure and function of the habitat
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
effects of sea lice medicines are not expected to affect this conservation objective.
9
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Processes supporting the habitat
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
effects of sea lice medicines are not expected to affect this conservation objective.
Distribution of typical species of the habitat
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
effects of sea lice medicines are not expected to affect this conservation objective.
Viability of typical species as components of the habitat
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
effects of sea lice medicines are not expected to affect this conservation objective.
No significant disturbance of typical species of the habitat
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling,
analysis and modelling, and are not effectively measurable. Thus the effects of smothering are not
expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental
Quality Standards (EQS) in the SAC. The modelling indicates that the dispersal plumes will not extend into
the SAC, and thus the effects of bath treatments are not expected to affect this conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which
equates to 0.03% of the far field Environmental Quality Standard (EQS). These changes are within the
margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the
10
Page 151
effects of sea lice medicines are not expected to affect this conservation objective.
Overall Conclusion
As a competent authority, Argyll and Bute Council has undertaken a Habitats Regulations appraisal and
appropriate assessment in consultation with SNH and SEPA. This assessment has been based on SEPAs
determination of a CAR licence for the development proposal, including their detailed Appropriate
Assessment (Annex 1) which is based on high-quality and extensive scientific data.
Having given consideration to the distance of the development proposal to the SAC boundary and
qualifying reef habitat; the proposed changes in deposition of solid waste and use of chemical
treatments from the existing Ardmaddy site; and cumulative nutrient enhancement, Argyll and Bute
Council conclude that the development proposal will not adversely affect the integrity of the Firth of
Lorn SAC, in light of its conservation objectives.
11
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1
April 2012
Page 1 of 22
The level of authorisation for marine fish farms under the CAR regime is classed as ‘complex’ and the materials have the potential to have a significant
effect upon the SAC, therefore a Habitats Regulations appraisal and appropriate assessment must be made. The potential hazards which can be
controlled through the CAR licensing process, either individually or in combination, are (a) smothering, (b) chemical treatments and (c) cumulative
nutrient enhancement. These only will be addressed below.
Lakeland Marine Farm Ltd. propose to relocate the cages at their Ardmaddy fish farm (CAR/L/1010472) to a new site at Ardmaddy South
(CAR/L/1099909), increase the licensed biomass and sea lice treatment chemicals.
Within or near (less than 3km) to the Firth of Lorn SAC there are seven licensed marine fin fish farms producing salmon at Port nan Seannag (Lunga)
(CAR/L/1000811), Ardmaddy (CAR/L1010472), Bagh Lachlainn (CAR/L/1025495), Port na Cro (CAR/L/1000810), South West Shuna
(CAR/L/1025496), Bagh Dail nan Ceann North & South (CAR/L/1004226), and Ardifuir (CAR/L/1021927). These sites are authorised by SEPA under
the Controlled Activity Regulations (CAR) and allowed to use certain listed chemicals for such activities as fish health, net anti-fouling and bio security.
For example, the farms are licensed to treat outbreaks of sea lice using a selection of chemical treatments, and licensed to use specific amounts
depending on many factors such as the size and location of the farm, and number of fish stocked at time of treatment.
Brief description of the project
27/04/2012
Project and site description
Date of completion:
Coordinating Officer: Naveed Bhatti, Marine Ecologist
Licence application number: CAR/L/1099909
Record of the assessment of the conservation implications of fin fish farm activity, in the Firth of Lorn Special Area of Conservation
SEPA’s duties under the Nature Conservation (Scotland) Act 2004 (section 15) and the Conservation Regulations 1994, (Regulations 48 and
49) during regulation
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 153
3
2
April 2012
Page 2 of 22
Annex I habitats present as a qualifying feature, but not a primary reason for the selection of this site:
· Not applicable.
Annex I habitats that are a primary reason for selection of this site:
· 1170 Reefs
This well-defined, discrete area encompasses a complex group of islands, sounds and inlets characterised by some of the strongest tidal
streams in the UK. The area is moderately exposed to wave action with very sheltered pockets enclosed by islands and skerries. Reefs extend
from the shallow depths between the islands and mainland into depths of over 200m, in many places close inshore. The varied physical
environment is reflected in the variety of reef types and associated communities and species, which are amongst the most diverse in both the
UK and Europe. These range from those characteristic of conditions sheltered from waves and currents, to those influenced by extreme tidal
streams. A rapid transition in communities occurs with the deceleration of the tidal streams. Species present include some which are normally
characteristic of deeper water (the sponges Mycale lingua and Clathria barleii, and the featherstar Leptometra celtica), and others which are
considered scarce (including the brown alga Desmarestia dresnayi). Many species occurring here have either a northern or southern-influenced
distribution and reach their geographic limits in this area, for example, the southern cup-coral Caryophyllia inornata, the nationally scarce
brittlestar Ophiopsila annulosa, and the northern bryozoans Bugula purpurotincta and Caberea ellisii.
Qualifying interests
(see http://jncc.defra.gov.uk/ProtectedSites/SACselection/sac.asp?EUCode=UK0030041)
The natural heritage interests of the Firth of Lorn SAC for which the site is designated are:
The general site character of the Firth of Lorn SAC is:
· Marine areas. Sea inlets (100%)
Qualifying interests for the SAC/SPA (habitats and/or species) and conservation objectives for each of these interests
Firth of Lorn, Argyll and Bute
Special Areas of Conservation or Special Protection Areas within the screening distance of the project
This appropriate assessment updates previous versions of the Firth of Lorn SAC appropriate assessment (including v1 Dec 2005, and v2 Sep 2011)
with regard to the Ardmaddy/Ardmaddy South fish farm sites and any cumulative effects. This appropriate assessment considers the development in
relation to the qualifying features and conservation objectives, using information gathered from the site and the most applicable modelling techniques.
This information has been collated from SEPA’s own data, as well as that submitted by the applicant.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 154
5
4
April 2012
Assessment of likely significant effect
Page 3 of 22
Identify the individual elements or phases of the overall project that would give rise to a likely significant effect. Clearly identify any element
No
Is the proposal directly connected with, or necessary to, conservation management of the SAC/SPA?
To avoid deterioration of the Annex I habitats (listed above) thus ensuring that the integrity of the site is maintained and the site makes an appropriate
contribution to achieving favourable conservation status for each of the habitats; and
To ensure for the Annex I habitats (listed above) that the following are maintained in the long term:
· extent of the habitat on site
· distribution of the habitat within site
· structure and function of the habitat
· processes supporting the habitat
· distribution of typical species of the habitat
· viability of typical species as components of the habitat
· no significant disturbance of typical species of the habitat.
Conservation Objectives
(see http://gateway.snh.gov.uk/sitelink/documentview.jsp?p_pa_code=8256&p_Doc_Type_ID=29)
Annex II species present as a qualifying feature, but not a primary reason for site selection:
· Not applicable.
Annex II species that are a primary reason for the selection of this site:
· Not applicable.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 155
April 2012
Page 4 of 22
Both the proposed and existing sites are outwith the SAC boundary, however, the proposed site is approximately 300m closer to the nearest part of
the SAC boundary at Cuan Sound. The existing site is 2.1km away and the proposed site 1.8km away from the SAC. The existing and proposed cage
locations and SAC boundary can be seen in Figure 1 below.
SAC features in the vicinity of the proposal
The potential hazards of the development upon the Annex I habitats are likely to be individually or in combination: (a) smothering, (b) chemical
treatments, and (c) cumulative nutrient enhancement and benthic impacts. These will be controlled through the CAR licensing process and each is
addressed separately below:
Lakeland Marine Farm Ltd proposes to
· relocate their site in Seil Sound from Ardmaddy, approximately 900m south, to Ardmaddy South
· change the type of cages from 18 x 24m x 24m x 10m deep cages to 12 x 100m circumference x 15m deep circular cages
· change the amounts of in-feed sea lice treatments for emamectin benzoate
· change the amounts of azamethiphos, cypermethrin and deltamethrin bath treatments
· change the cage surface area from 10,368m2 to 9549m2
· increase the biomass from 1300t to 2500t
· the proposed extent of moorings at the new site is 179,800m2
· no change to the species farmed salmon.
Proposal Details
of the project where the scale or magnitude of effect is not known or cannot be determined at this stage.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 156
April 2012
Page 5 of 22
Few studies have been undertaken to evaluate the effects of different levels of solids flux on reef organisms. The solids flux:ITI relationship has been
empirically determined specifically for benthic infauna, and therefore is not applicable to reef fauna; however, it likely that some reef fauna will be more
sensitive to solids flux. This is indicated by those relevant reef organisms to which are assigned AMBI (AZTI Marine Biotic Index) scores:
Effects on reef species
Figure 1. Proposed cage locations (red circles) and SAC boundary for the proposed Ardmaddy South and existing Ardmaddy fish farm sites
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 157
April 2012
Page 6 of 22
For synthetic compounds and hydrocarbon contamination, the habitats and species were assessed against mass mortality (both short- and long-term),
For suspended sediment, the habitats were assessed against 100mg/l for one month. MarLIN indicates that the above habitats are not sensitive or
have a very low sensitivity to an increase in suspended sediment. This is due to their low intolerance and either immediate or very high recoverability.
The habitats have been assessed against smothering by 5cm of sediment for one month. MarLIN indicates that the habitats CR.LCR.BrAs.AntAsH,
CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri will have a moderate sensitivity to smothering, due to their high intolerance but moderate
recoverability. The habitat CR.MCR.EcCr.FaAlCr.Pom has an intermediate intolerance to smothering, but a low sensitivity due to its high recoverability.
The MarLIN website www.marlin.ac.uk has assessed available information on the sensitivity of different species and habitats to various factors,
including smothering, increase in suspended sediment, synthetic compound contamination, hydrocarbon contamination and changes in nutrient levels.
For those species listed in the qualifying interests, no information is available or they are not listed. Information is available for four types of reef
habitats which are likely to be found in the SAC, namely,
· Antedon spp., solitary ascidians and fine hydroids on sheltered circalittoral rock CR.LCR.BrAs.AntAsH
http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=313&code=2004
· Neocrania anomala and Protanthea simplex on very sheltered circalittoral rock CR.LCR.BrAs.NeoPro
http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=5&code=2004
· Ophiothrix fragilis and/or Ophiocomina nigra beds on slightly tide-swept circalittoral rock or mixed substrata CR.MCR.EcCr.CarSp.Bri
http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=278&code=2004
· Faunal and algal crusts, Echinus esculentus, sparse Alcyonium digitatum and grazing-tolerant fauna on moderately exposed circalittoral rock
CR.MCR.EcCr.FaAlCr.Pom http://www.marlin.ac.uk/habitatsensitivity.php?habitatid=337&code=2004.
The taxa noted from the SAC (see §3 above) with AMBI scores assigned, e.g. Dendrodoa grossularia, Corynactis viridis, Caryophylla inornata,
Ophiopsila annulosa, all fall into group I.
AMBI scores are assigned as follows [see Borja, A., J. Franco & V. Pérez (2000) A Marine Biotic Index to Establish the Ecological Quality of SoftBottom Benthos Within European Estuarine and Coastal Environments. Marine Pollution Bulletin 40 (12) 1100 – 1114]:
· Group I – Species very sensitive to organic enrichment and present under unpolluted conditions. They include the specialist carnivores and
some deposit feeding tubiculous polychaetes.
· Group II – Species indifferent to enrichment, always present in low densities with insignificant variations with time. These included suspension
feeders, less selective carnivores and scavengers.
· Group III – Species tolerant to excess organic matter enrichment. These species may occur under normal conditions, but their populations are
stimulated by organic enrichment. They are surface deposit-feeding species, as tubiculous spionids [polychaetes].
· Group IV – Second-order opportunistic species. Mainly small sized polychaetes: subsurface deposit-feeders, such as cirratulids.
· Group V – First-order opportunistic species. These are deposit feeders, which proliferate in reduced sediments.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 158
April 2012
Page 7 of 22
The modelled output of solids flux around the fish farm cage groups are shown in Figure 2 below. The edge of the Allowable Zone of Effect (AZE) is
modelled at 192gm-2yr-1, which is equivalent to the 30ITI boundary. This modelling has been produced by the applicant, and subsequently validated,
checked and approved by SEPA. More information on the modelling methodology may be found in SEPA’s Fish Farm Manual at
http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx
The deposition of waste feed and faecal particles has the potential to smother reef habitat and associated species. SEPA uses the bespoke particletracking model AutoDepomod to determine the sea bed deposition footprint of particles leaving the cages and also any re-suspension of deposited
material to the wider area.
a) Receptor: solids flux smothering
For changes in nutrient levels, MarLIN indicates the habitats CR.LCR.BrAs.AntAsH, CR.LCR.BrAs.NeoPro and CR.MCR.EcCr.CarSp.Bri will have a
low sensitivity or are not sensitive, due to a high recoverability and low intolerance. The habitat CR.MCR.EcCr.FaAlCr.Pom will have a moderate
sensitivity, due to a high intolerance but high recoverability.
For hydrocarbon contamination, MarLIN indicates the habitat CR.LCR.BrAs.AntAsH will have a moderate sensitivity, due to a high intolerance but high
recoverability. There is insufficient information for the habitat is CR.LCR.BrAs.NeoPro, but this is expected to show a similar response to
CR.LCR.BrAs.AntAsH. The habitats CR.MCR.EcCr.CarSp.Bri and CR.MCR.EcCr.FaAlCr.Pom are both listed as having a low sensitivity, due to their
low or intermediate intolerance and high recoverability.
MarLIN indicates that the habitats CR.LCR.BrAs.AntAsH and CR.MCR.EcCr.FaAlCr.Pom have a moderate sensitivity to synthetic compound
contamination, due to a high intolerance but high recoverability. There is insufficient information for the habitats CR.LCR.BrAs.NeoPro and
CR.MCR.EcCr.CarSp.Bri, however they are also expected to show a moderate sensitivity, high intolerance and high recoverability.
a reduction in abundances, and sub-lethal effects such as a reduced reproductive potential.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 159
177400
177600
177800
178000
178200
1
176900
713000
713100
713200
713300
713400
713500
713600
713700
713800
713900
177100
177300
177500
177700
Proposed application (Ardmaddy S)
-100
-50
-4
0
2
5
10
20
30
40
50
60
70
80
90
100
Depth (m)
1
10
50
192
1000
5000
10000
15000
Flux (g/m2/yr)
April 2012
Existing site
1300t
530,824kg
528,859kg
100
Proposed site
2500t
1,020,838kg
598,930kg
59
% increase
92
92
13
Page 8 of 22
It is reasonable to assume that the solids which are not exported, will be subject to natural degradation processes within the model domain, and so will
not affect the SAC or its features. The amount of solids exported is modelled to increase by 70,071kg/yr, the fate of which will be examined in more
detail. This increase represents less than 3% of the total solids exported from all the fish farms within, or near to the SAC boundary, and within Seil
Maximum biomass
Release of solids
Export
% export
Table 1. AutoDepomod predictions of solids exported from the fish farm sites
The proposed site-specific AZE footprint is larger than existing footprint. This is because the proposed site is located in deeper water with relatively
more quiescent conditions. AutoDepomod predicts that approximately 60% of the solids will be exported from the model domain for the proposed site,
cf. nearly 100% for the existing site. The proposal will result in a 13% increase of solids exported from the modelled domain (see Table 1 below).
177200
714200
714300
714400
10
50
5
2
0
-4
-50
-100
192
10
714500
714600
1000
5000
10000
15000
Flux (g/m2/yr)
40
30
20
70
60
50
90
80
100
Depth (m)
714700
714800
714900
715000
Existing licence (Ardmaddy)
Figure 2. Modelled benthic footprint for solids flux around the Ardmaddy & Ardmaddy S cage groups
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 160
April 2012
Page 9 of 22
The SARF study also found that AutoDepomod overestimates the amount of solids exported from the model domain, as it does not account for
material which was previously exported but which later returns to the model domain. This provides conservatism to the modelled outcomes, and in
A report for SARF investigated the exported solids from the fish farms in the Seil Sound and Shuna Sound area (The Fate of Particulate Wastes
Arising From Fish Farm Sites (SARF Project 37) see http://www.sarf.org.uk/cms-assets/documents/28813-936945.sarf035---fina1report---nov07.pdf
[accessed 20/3/12]). Modelling results from this predicted that 67% of the solids from the Ardmaddy site would enter the SAC via Cuan Sound and 2%
via the southern boundary. If the locations of all the fish farms in the SARF study are compared, it can be reasonably assumed that the Ardmaddy and
Ardmaddy South sites will be similar to each other in terms of the proportions of solids exported into the SAC. The high current speeds and dynamic
environment in the Cuan Sound and Sound of Luing mean that these solids are not likely to settle within the Cuan Sound or its vicinity, but will be
transported more widely within the SAC and beyond. This means that, if for instance all the material exported into the SAC is evenly distributed only
within the SAC (and not transported further in the Firth of Lorn), the increase in the sedimentation rate would be 0.2gm-2yr-1 (using 210km2 for the area
of the SAC). Such an increase in sedimentation in the SAC would represent approximately 0.00001% of the observed background levels.
Background concentrations are reported to be 5–10gm-3 [Perry 2010 ibid., see also Dale, A. C. & T. J. Sherwin (2011) Scallop dredging in the Firth of
Lorn Marine SAC: modelling of indirect environmental impacts Scottish Natural Heritage Commissioned Report 414], which compare to the maximum
concentrations underneath the cages of 0.01gm-3 and outside the modelled grid of 0.000001gm-3. It is interesting to note that a recent investigation into
the effects of dredging in the Firth of Lorn SAC, found typical maximum concentrations of 0.1gm-3 after one tidal cycle, when the levels of suspended
silt in the water column after a simulated dredging event were examined the (Dale & Sherwin 2011).
Natural rates of deposition in the Firth of Lorn SAC have been investigated by Perry (see Perry (2010) Sedimentation in the Firth of Lorn, Marine
Special Area of Conservation (Marine Scotland Science report) see http://www.scotland.gov.uk/Resource/Doc/295194/0107877.pdf [accessed
20/3/12]). The results found that natural sedimentation rates ranged from 1–60µl/l, but were more typically 2–13µl/l. The sedimentation rates
underneath the fish farm cages (using a flux rate of 10000gm-2yr-1)would equate to less than 1% of the lowest rates observed naturally, and that
outside the modelled grid (using a flux rate of 1gm-2yr-1) would be less than 0.001%. These natural sedimentation rates were measured near the
Garvellachs Island groups (Eileach an Naoimh), which is a relatively exposed location, however it does indicate that there are large amounts of
suspended sediment being transported naturally within the SAC, and that the hydrographically dynamic environment of the SAC will spread the solids
exported from the fish farm widely.
Sound and the Sound of Shuna (i.e. for fish farms at Ardifuir (CAR/L/1021927), Port nan Seannag (Lunga) (CAR/L/1000811), Ardmaddy
(CAR/L1010472), Bagh Lachlainn (CAR/L/1025495), Port na Cro (CAR/L/1000810), South West Shuna (CAR/L/1025496), Bagh Dail nan Ceann North
& South (CAR/L/1004226), and Shuna Castle Bay (CAR/L/1000801). Note that the two sites in neighbouring Loch Melfort, Eilean Coltair
(CAR/L/1000197) and Kames Bay (CAR/L/1000237), have been excluded from the evaluation, due to (i) their distance from the nearest point of the
SAC boundary (Kames Bay is 8.1km away, and Eilean Coltair 6.1km), and (ii) their low prospect of increasing the amounts of solids in the wider area
as they are in relatively quiescent situations. For example only 0.005% of solids released at Eilean Coltair is expected to be exported from the site.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 161
April 2012
Page 10 of 22
This means it is reasonable to conclude that any potential impacts due to changes in solids flux on the SAC designated features will be negligible and
will not compromise the site’s Conservation Objectives. This conclusion is based upon the most up-to-date scientific research, and best available
rigorous modelling.
The levels of smothering and sedimentation are negligible compared with those used for the MarLIN sensitivity assessments for relevant reef habitats,
and the increase in solids flux over the background levels would not be effectively measurable. This combined with the generally dispersive nature of
the SAC and beyond, means it is reasonable to conclude that the proposed changes in solids flux will not give rise to a likely significant effect on the
SAC designated features.
However, the above assessment leads to the conclusion that the proposal will result in a relatively small (<3%) increase of solids from fish farms in the
general area of the SAC. The reported natural sedimentation rates in the SAC are relatively high, and the increase in sedimentation in the SAC,
resulting from the proposal, represents 0.00001% of the natural background rates.
Summary of solids flux impacts
The proposed changes in solids flux may give rise to a likely significant effect. This likely significant effect is due to the predicted export of solids
emanating from the proposed fish farm being transported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary
(2%).
Therefore, it can be reasonably concluded that
· the increase in solids exported from the proposed Ardmaddy South site is negligible when compared to the amounts already exported from
neighbouring fish farms in the Seil Sound and Sound of Shuna area
· any solids exported into the SAC will be widely distributed, both within the SAC and beyond
· the amounts of solids resulting from fish farms in the SAC are many orders of magnitude below the natural sedimentation rates, and can thus
be considered insignificant.
reality, the amounts of solids from the fish farms in the SAC should be less.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 162
April 2012
Page 11 of 22
Bath treatments
The proposed quantities and those for the existing licence, of bath chemical treatments (azamethiphos, cypermethrin and deltamethrin) are shown in
Table 2 (below). The amounts of cypermethrin and deltamethrin are slightly higher than previous licensed (both representing ~50% increase). Note,
however, that for azamethiphos, the 3hr discharge limit is not used as it would exceed the 24hr limit, thus there will be a 63% decrease for this
particular chemical. The amounts licensed previously also used the Environmental Quality Standards (EQS) determined from modelling. The model
takes into account the dispersing plumes and the EQS, and the mixing zone is defined as the lower of 0.5km 2 or 2% of the loch area (for more
information on the modelling methodology see SEPA’s Fish Farm Manual Annex G at
These chemicals are not naturally persistent and break down via hydrolysis and photolysis to non-toxic components, though this may vary under
different conditions. For example the half-life of emamectin benzoate in anaerobic sediments is 164–175 days, whereas photolysis is known to
accelerate its breakdown and may reduce the half-life to 0.7 days in seawater. The half-life used for AutoDepomod is 250 days, and so is conservative.
[see e.g. McHenery, J.G. and C. M. Mackie (1999). Revised expert report on the potential environmental impacts of emamectin benzoate, formulated
as Slice®, for salmonids. Cordah Report No.: SCH001R5, Schering-Plough Animal Health (2002) Potential environmental impacts of emamectin
benzoate, formulated as Slice ®, for salmonids. Technical Report 36 pp., Bright D. A. and S. Dionne (2005) Use of emamectin benzoate in the
Canadian finfish aquaculture industry: a review of environmental fate and effects. UMA Engineering Report for Environment Canada (accessed on
24/2/12) http://dsp-psd.pwgsc.gc.ca/Collection/En4-51-2005E.pdf, SEPA Fish Farm Advisory Group (1999) Emamectin Benzoate An Environmental
Risk Assessment. 23 pp.]
Cypermethrin concentrations in the water column are virtually non-detectable within an hour of treatment, having no measurable effect on zooplankton,
and is thought to have a half life of 35 days in organic marine sediments (2005 SAMS Research Project: PAMP (2005) The Ecological Effects of Sea
Lice Medicines in Scottish Sea Lochs).
Hydrogen peroxide (Paramove®, Salartect®) is also licensed for used as a sea lice treatment, however, this quickly breaks down into water and
oxygen, and is therefore not considered hazardous to marine organisms.
Sea lice medicine residues, both in the water column and in the sediment, have the potential to be toxic to reef habitat and associated species. The
principal materials that may affect sea bed fauna are the sea lice bath treatments azamethiphos (trade name Salmosan®), cypermethrin (trade name
Excis®) and deltamethrin (trade name AMX®), and the in-feed treatments emamectin benzoate (the active ingredient of Slice®) and teflubenzuron (the
active ingredient of Calicide®). These products are licensed by SEPA for use against sea lice infestations on salmon farms. Limits are imposed on the
amounts of these products licensed to discharge, and these are calculated using the AutoDepomod model. The limits imposed ensure that the
residues arising from amounts of the material used are within SEPA standards set to protect flora and fauna, standards known as Environmental
Quality Standards (EQS). These standards are derived from toxicity studies on sensitive organisms, and then a safety factor of between 10 and 100 is
then applied.
b) Receptor: toxic effects from sea lice treatments
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 163
April 2012
87.5
236.2
324.3
238.7
24hr discharge
42.8
65.0
Cypermethrin (g)
3hr discharge
16.0
24.4
Deltamethrin (g)
3hr discharge
Proposed (Ardmaddy S—
CAR/L/1099909)
Existing licence (Ardmaddy—
CAR/L/1010472)
455.0
1245.5
Page 12 of 22
875.0
1654.1
Emamectin benzoate (g)
Total Allowable Quantity
Maximum Treatment Quantity
(TAQ)
(MTQ)
Table 3. Quantities of sea lice in-feed treatments
1351.1
1358.0
Teflubenzuron (g)
In-feed treatments
The proposed quantities and those for the existing licence, of in-feed chemical treatments (emamectin benzoate and teflubenzuron) are shown in
Table 3 (below).
Proposed (Ardmaddy S—
CAR/L/1099909)
Existing licence (Ardmaddy—
CAR/L/1010472)
Azamethiphos (g)
3hr discharge
Table 2. Quantities of sea lice bath treatments
Therefore, it is concluded that any potential impacts due bath treatment use within the EQS will be negligible and will not compromise the site’s
conservation objectives.
http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx). The proposed amount of
azamethiphos is significantly less than that for the existing licence, so this proposal will result in a lower risk of potential impact in the SAC.
Cypermethrin and deltamethrin are readily bound to particles, and are rapidly removed from the water column. Furthermore, the data from the current
meters deployed at the proposed site show that the mixing zone will not be taken directly toward the SAC boundary at Cuan Sound.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 164
April 2012
Page 13 of 22
The far field Environmental Quality Standard (EQS) for emamectin benzoate is set at 100 times less than the toxicity tests thresholds, and the near
field at 10 times less. Therefore, there is some considerable degree of safety built in to the modelled footprint at the near and far fields. These toxicity
tests have been based on No Observable Effect Concentrations for studies carried out on the most sensitive species such as Crangon crangon,
Nephrops norvegicus, Corophium volutator, Arenicola marina and planktonic copepods. The model predicts higher emamectin benzoate
concentrations in the sediments at the cage edge than the standard of 7.63µg/kg (Fig. 3). This is because the near field area is calculated using
7.63µg/kg as the mean value within it.
Emamectin benzoate
The applicant proposes an increase in the amounts of emamectin benzoate licensed (Table 3). The output plots from the model runs for emamectin
benzoate in the sediments are included below (Fig. 3). The extent and area of the proposed emamectin benzoate footprint is similar to that of the
proposed benthic 30ITI AZE (see Figs. 2, 3).
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 165
April 2012
177400
177600
177800
178000
178200
-100
0
-4
-50
20
10
5
2
50
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30
80
70
60
100
90
0.76
7.63
177200
714200
714300
714400
714500
714600
714700
714800
714900
715000
177400
177600
177800
178000
178200
-100
0
-4
-50
20
10
5
2
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40
30
80
70
60
100
90
0.10
0.30
0.76
7.63
25.00
50.00
76.30
100.00
125.00
150.00
175.00
200.00
225.00
250.00
Depth (m) EmBz (mic-g/kg)
Existing licence—predicted near-field and far-field AZES
177200
714200
714300
714400
714500
714600
714700
714800
714900
715000
Depth (m) EmBz (mic-g/kg)
Existing licence—predicted near-field and far-field AZES
177000
177200
177400
177600
177800
-100
-4
-50
5
2
0
20
10
60
50
40
30
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0.76
7.63
177000
Page 14 of 22
713000
713100
713200
713300
713400
713500
713600
713700
713800
177200
177400
177600
177800
-4
-50
-100
10
5
2
0
30
20
60
50
40
80
70
100
90
0.10
0.30
0.76
7.63
25.00
50.00
76.30
100.00
125.00
150.00
175.00
200.00
225.00
250.00
Depth (m) EmBz (mic-g/kg)
Proposed application—predicted near-field and far-field AZES
713000
713100
713200
713300
713400
713500
713600
713700
713800
Depth (m) EmBz (mic-g/kg)
Proposed application—predicted near-field and far-field AZES
Figure 3. Modelled benthic footprints for emamectin benzoate residues in sediments around the Ardmaddy & Ardmaddy S cage groups
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 166
April 2012
Page 15 of 22
The far field and near field Environmental Quality Standards (EQS) for teflubenzuron are set according to toxicity tests thresholds, in a similar manner
to emamectin benzoate, and therefore there is some considerable degree of safety built in to the modelled footprint at the near and far fields. These
toxicity tests have been based on No Observable Effect Concentrations for studies carried out on the most sensitive species such as Crangon
crangon, Nephrops norvegicus, Corophium volutator, Arenicola marina and planktonic copepods. The cage edge standard is 10mg/kg, and the far field
standard 2mg/kg.
Teflubenzuron
The applicant proposes a very small increase in the amount of teflubenzuron licensed. The output plots from the model runs for teflubenzuron in the
sediments are included below (Fig. 4) (for more information on the modelling methodology see SEPA’s Fish Farm Manual Annex H at
http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx).
The model permits higher quantities of emamectin benzoate to be used at the proposed Ardmaddy South site due to more residues being retained
within the model domain. The licence therefore also limits the amounts of in-feed chemicals according to the amounts exported from the site, and this
is assessed for compliance against the far field Environmental Quality Standard (EQS) for 10km 2 (or for 50% of constrained areas) [for more
information on the modelling methodology see SEPA’s Fish Farm Manual Annex H at
http://www.sepa.org.uk/water/water_regulation/regimes/aquaculture/marine_aquaculture/fish_farm_manual.aspx]. A proportion of emamectin benzoate
residues will therefore be exported from the model grid, in a similar manner to the solids wastes. An estimated 67% of these residues will be exported
into the SAC via the Cuan Sound and 2% via the southern boundary (SARF 37 ibid.) and the impact of these residues in the wider SAC will be
evaluated in more detail below.
For the existing Ardmaddy site, the operator returned actual sediment data for emamectin benzoate residues from samples taken in 2010. The
sediments values were 0.4µg/kg and 0.6µg/kg at 100m from the cages and 0.6µg/kg at the cage. These results, and those from previous surveys, are
all below the cage edge standard of 7.63µg/kg, and below the far field standard of 0.763µg/kg. The samples were collected at the time of maximum
excretion from the fish.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 167
April 2012
177400
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178000
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-4
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60
0.00
0.00
0.00
1.00
0.50
0.10
4.00
3.00
2.00
15.00
10.00
5.00
30.00
25.00
20.00
35.00
100
90
713000
713100
713200
713300
713400
713500
713600
713700
713800
177000
177200
177400
177600
177800
-100
-4
-50
2
0
20
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30
50
40
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70
60
90
100
Depth (m)
0.00
0.00
0.00
0.50
0.10
3.00
2.00
1.00
4.00
10.00
5.00
25.00
20.00
15.00
35.00
30.00
TfBz (g/kg)
Proposed application—predicted near-field and far-field AZES
Page 16 of 22
It is therefore reasonable to conclude that there will be no significant impacts in the SAC due to the licensed amounts of teflubenzuron. However,
teflubenzuron residues will be exported from the model grid, in a similar manner to the solids wastes and emamectin benzoate, and the impact of this
in the wider SAC will be evaluated in more detail below.
Due to the export of residues from the site, similarly to emamectin benzoate, the model limits the amount of teflubenzuron at both the proposed and
existing sites. This means the equivalent treatable biomass is 19.3t for Ardmaddy and 19.4t for Ardmaddy South. The amount of teflubenzuron
licensed is therefore not practical for treating the fish, and so it has not been used historically at the Ardmaddy site. No sediment data for teflubenzuron
residues is therefore available. As only 19.4t of stock can be treated with teflubenzuron at the proposed Ardmaddy South site, its use here is not
expected either.
177200
714200
714300
714400
714500
714600
714700
714800
714900
715000
TfBz (mg/kg)
Depth (m)
Existing licence—predicted near-field and far-field AZES
Figure 4. Modelled benthic footprints for teflubenzuron residues in sediments around the Ardmaddy & Ardmaddy S cage groups
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 168
April 2012
Emamectin benzoate
921.7g
929.0g
7.3g
0.8%
Teflubenzuron
1216.0g
1220.2g
4.2g
0.3%
Ardmaddy (existing licence)
636g
3.03µg/m2
3.29%
Ardmaddy South (proposal)
641g
3.05µg/m2
3.31%
Increase
5g
0.02µg/m2
0.03%
Page 17 of 22
It is also important to consider the decay of emamectin benzoate residues and metabolites. The half-life in anaerobic sediments is 164–175 days, but
may be as low as 0.7 days in seawater. A recent SEPA survey found a half-life of 58–93 days for emamectin benzoate, and no metabolites in the
Proportion exported to the SAC is calculated as 69% as per SARF report (The Fate of Particulate Wastes Arising From Fish Farm Sites (SARF Project 37) see
http://www.sarf.org.uk/cms-assets/documents/28813-936945.sarf035---fina1report---nov07.pdf [accessed 20/3/12]). Modelling results from this predicted that 67% of
the solids from the Ardmaddy site would enter the SAC via Cuan Sound and 2% via the southern boundary.
ii
This assumes all residues are retained in the SAC and not distributed further: due to the strong currents in the Sound of Cuan and Sound of Luing, combined with
the low settling rates of the suspended particles reaching the SAC, mean the residues will be distributed widely and thus fairly evenly distributed in the SAC. (This is
conservative as it is likely the residues will be distributed beyond the SAC).
iii
The far field Environmental Quality Standard (EQS) is 0.763µg/kg
i
Export to SAC
Distribution in SACii
Proportion of far field EQSiii
i
Table 5. Fate of emamectin benzoate residues exported into the SAC
These exported residues may be transported into the SAC, in a similar way to the solids residues. As the licensed quantities for teflubenzuron are too
small to allow an effective treatment of the stocked fish, only the fate of the emamectin benzoate residues will be evaluated further. It can be seen that
these amounts are very small, and if these increased amounts of emamectin benzoate were spread evenly in the SAC, this would represent 0.03% of
the far field Environmental Quality Standard (EQS) (see Table 5).
It can be seen that the relative increase is very small, and below a statistical significance level of 1%. Such a minor change is within the margins of
error e.g. for sampling, analysis, and the model.
Export from Ardmaddy
Export from Ardmaddy S
Increase in export
Increase in export
Table 4. AutoDepomod predictions of in-feed residues exported from the fish farm sites
Fate of sea lice in-feed residues in the SAC
The changes in the amounts of in-feed sea lice chemicals which will be exported from the modelled grid are shown in Table 4 (below).
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 169
6
April 2012
Page 18 of 22
Cumulative effects due to an increased biomass on the water quality and nutrient status may occur. Currently the sole means of determining carrying
capacity for fish farms in a waterbody is by use of the Locational Guidelines. The existing Ardmaddy and proposed Ardmaddy South fish farm sites are
not within a SEERAD Category area. This means the area has sufficient flushing to dilute and disperse the chemicals released from the fish farms
such that, taken in combination, they do not breach Environmental Quality Standards (EQS). Any changes to cumulative effects due to the proposal
c) Receptor: cumulative effects
Identify any likely direct, indirect or secondary impacts of the project, in combination with other plans or projects, on the SAC/SPA.
This means it is reasonable to conclude that any potential impacts due to the use of licensed sea lice treatments will be negligible and will not
compromise the site’s Conservation Objectives. This conclusion is based upon the most up-to-date scientific research, and best available rigorous
modelling.
For in-feed treatments, the likely significant effect is due to the predicted export of sea lice treatment residues emanating from the proposed fish farm,
being exported into the Firth of Lorn SAC, through both the Cuan Sound (67%) and the southern boundary (2%). However, the above assessment
leads to the conclusion that the proposal will result in a very small (<1%) increase of sea lice residues. This amount is not statistically significant (at the
1% or 5% levels), and is well within the margins of error for sampling, analysis and the model. Furthermore, the increase in the SAC is equivalent to
0.03% of the far field Environmental Quality Standard (EQS) of 0.763µg/kg. Such an increase is not effectively measurable, and this combined with the
generally dispersive nature of the SAC and beyond, means it is reasonable to conclude that the proposed changes in sea lice treatments will not give
rise to a likely significant effect on the SAC designated features.
For bath treatments, the likely significant effect is due to the treatment plumes dispersing from the proposed fish farm and being transported into the
Firth of Lorn SAC, mainly through the Cuan Sound. However, the modelling indicates that the dispersal plumes are not taken directly toward the SAC,
and therefore the 0.5km2 mixing zone will not extend into the SAC. This means that bath treatment levels within the SAC will all be below the
Environmental Quality Standards (EQS). This combined with the generally dispersive nature of the SAC and beyond, allows the above assessment to
lead to the conclusion that the proposed changes in licensed bath treatments will not give rise to a likely significant effect on the SAC designated
features.
Summary of sea lice treatment impacts
The proposed changes in the use of licensed sea lice treatments may give rise to a likely significant effect. The MarLIN sensitivity assessments do not
examine the effects of specific sea lice treatments on reefs, but tests on the most sensitive taxa have been used to determine the Environmental
Quality Standards (EQS).
sediments—the metabolites appeared to break down even faster. The half-life used for AutoDepomod is 250 days, and so is conservative, therefore, in
reality, the amounts in SAC will be significantly less than those calculated above.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 170
10
9
8
7
April 2012
Appropriate Assessment
Page 19 of 22
The relevant conservation objectives are:
To avoid deterioration of the Annex I habitat (reefs) thus ensuring that the integrity of the site is maintained and the site makes an appropriate
contribution to achieving favourable conservation status for each of the habitats; and
To ensure for the Annex I habitat (reefs) that the following are maintained in the long term:
· distribution of the habitat within site
· structure and function of the habitat
The Annex I habitat of the Firth of Lorn SAC which will be affected by marine fish farm operations is reefs.
Identify the relevant conservation objectives to consider for the SAC/SPA.
No
Is the plan/project likely to have a significant effect on the SAC/SPA, either alone or in combination, with other plans or projects?
Conclusion of assessment of likely significant effect
List any remaining likely significant effects, or identify those for which it is not possible to determine that there is no likely significant effect.
The CAR licence also contains site-specific numeric limits for sea lice treatments such that their authorised use will not be predicted to exceed EQS.
Environmental monitoring built into the licence will pick up residues of treatments and enforcement action is taken if these are exceeded.
The CAR licence for the fish farm contains site-specific numeric limits for the maximum biomass such that the solids flux will not be predicted to
exceed the modelled Environmental Quality Standards (EQS). Environmental monitoring is built into the licence and enforcement action is taken if
these are exceeded.
Identify standard conditions within the authorisation, or other conditions agreed with the applicant, which will remove the risk of likely
significant effects listed above.
are therefore considered negligible.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 171
13
12
11
processes supporting the habitat
distribution of typical species of the habitat
viability of typical species as components of the habitat
no significant disturbance of typical species of the habitat.
April 2012
·
Page 20 of 22
Distribution of the habitat within site:
The proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001% of the natural background rates.
These changes are within the margins of error for sampling, analysis and modelling, and are not effectively measurable. Thus the effects of
smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
The conclusion of the assessment of likely significant effect is that there will be no likely significant effect. However, SNH have advised that an
appropriate assessment should be undertaken as part of this Habitats Regulations appraisal, and this should consider each of the relevant
conservation objectives, justifying why each is maintained.
Can it be ascertained beyond reasonable scientific doubt that the proposal will not adversely affect the integrity of the SAC/SPA?
Conclusion of Appropriate Assessment
List any remaining likely significant effects, or identify those for which it is not possible to determine that there is no likely significant effect.
The numeric conditions placed within SEPA’s CAR licences are robust and enforceable. SEPA will act upon evidence and data suggesting that
numeric limits have been breached. These limits are not negotiable with the applicant as they are there to protect the environment, and their
thresholds are set to protect the most sensitive fauna using a well-tried and tested process of Environmental Quality Standards (EQS) setting and
additional inbuilt safety factors. SEPA believes that the above will provide appropriate mitigation to help avoid impacts on the site’s integrity with
respect to its conservation objectives.
Identify any enforceable conditions agreed with the applicant, which will remove the risk of likely significant effect from the elements of the
project listed above.
·
·
·
·
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 172
April 2012
Processes supporting the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and 0.0001%
of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not effectively
measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Distribution of typical species of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Viability of typical species as components of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to
fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling,
·
·
·
Page 21 of 22
Structure and function of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to fish farms, and
0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
·
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 173
No significant disturbance of typical species of the habitat: the proposal will result in changes in solids flux in the SAC of 3% of the total due to
fish farms, and 0.0001% of the natural background rates. These changes are within the margins of error for sampling, analysis and modelling,
and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
Page 22 of 22
Therefore, in the view of SEPA, and in consultation with SNH, impacts from solids flux, sea lice treatments and nutrients are calculable and will not
have an adverse effect on the SAC features or conservation interests of the site.
As a competent authority, SEPA has undertaken a Habitats Regulations appraisal and appropriate assessment. This assessment has been based on
high-quality and extensive scientific data, and uses the latest available information. A rigorous scientific conclusion may therefore be reached.
there will be no adverse effect on the SAC site integrity.
Therefore the distance of the site to the SAC boundary, and any potential designated features, in combination with the proposed changes in solids flux,
chemical treatments and cumulative nutrient enhancement (as evaluated above), lead to the conclusion:
·
April 2012
and are not effectively measurable. Thus the effects of smothering are not expected to affect this conservation objective.
The proposed use of sea lice bath treatments will not result in any exceedance of the Environmental Quality Standards (EQS) in the SAC. The
modelling indicates that the dispersal plumes will not extend into the SAC, and thus the effects of bath treatments are not expected to affect this
conservation objective.
The proposal will result in changes in sea lice treatment residues in the SAC of amounts of <1%, which equates to 0.03% of the far field
Environmental Quality Standard (EQS). These changes are within the margins of error for sampling, analysis and modelling, and are not
effectively measurable. Thus the effects of sea lice medicines are not expected to affect this conservation objective.
ANNEX 1 – SEPA Habitats Regulations Appraisal of fin fish activity in the Firth of Lorn SAC
Page 174
176200
Page177400
175
176800
178000
178600
Wa
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Page 176
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Page 177
Agenda Item 7
Argyll & Bute Council
Development & Infrastructure
Delegated or Committee Planning Application Report and Report of handling as required
by Schedule 2 of the Town and Country Planning (Development Management Procedure)
(Scotland) Regulations 2008 relative to applications for Planning Permission or Planning
Permission in Principle
____________________________________________________________________________
Reference No:
12/01520/PP
Planning Hierarchy: Local
Applicant:
West Highland Housing Association and Arcade Building Services Ltd
Proposal:
Formation of roundabout to serve future development land north and
south of the A85, Dunbeg, Oban.
Site Address:
Land South West Of Pennyfuir Cottage, Dunbeg, Oban
____________________________________________________________________________
DECISION ROUTE
(i)
Local Government Scotland Act 1973
____________________________________________________________________________
(A)
THE APPLICATION
(i)
Development Requiring Express Planning Permission
•
•
(ii)
Formation of new vehicle roundabout on A85 Trunk Road;
Alterations to existing footpaths, formation of new footpath and formation of
cycle path on redundant carriageway
Other specified operations
•
Connection to public drainage system.
____________________________________________________________________________
(B)
RECOMMENDATION:
This proposal is recommended for approval subject to:
i)
a discretionary Local Hearing being held in view of the number of representations
which have been received;
ii) the conditions and reasons listed in this report
____________________________________________________________________________
Page 178
(C)
HISTORY:
There is no planning history for this particular site. However, there is planning history for
other sites of relevance to this proposal which are as follows:
08/00189/OUT – Application in principle for the formation of a Class 4 Business
Park/Science Park development including improvements to the existing access road,
Dunstaffnage Mains Farm, Dunbeg – Application Approved 28th July 2008.
10/01156/AMSC – Approval of conditions 1, 4, 5, 9, 10, 11, 18, 21, 22, 24, 25 and 26 in
relation to Phase 1 of the development approved in principle by: outline planning
permission reference 08/00189/OUT, Dunstaffnage Mains Farm, Dunbeg – Application
Approved 29th September 2010.
11/02248/PP – Erection of 50 dwellings (comprising 14 houses and 36 flats), Land North
of Dunstaffnage Mains Farm, Dunbeg – Application Approved 22nd August 2012.
12/00575/AMSC – Approval of conditions 1, 2, 3, 4, 5, 8, 9 and 24 in relation to Phase 2
and 3 of the development approved in principle by outline planning permission,
Dunstaffnage Mains Farm, Dunbeg – Application Approved 27th September 2012.
12/01241/PPP - Site for the erection of dwellinghouse and removal of existing chalet and
sheds on Garden Ground of Pennyfuir Cottage, Dunbeg, Oban, Argyll & Bute, PA37 1PX
____________________________________________________________________________
(D)
CONSULTATIONS:
Scottish Water (30th July 2012) – no objection
Area Roads (27th July 2012) – no objection
Transport Scotland (12th March 2013) – no objection subject to a condition requiring
the roundabout to be constructed to a layout and type (and method) of construction
which meets with the approval of Transport Scotland, as the Trunk Roads Authority.
Dunbeg Community Council (20th September 2012) – object further to a unanimous
decision from those villagers present at a meeting on the 10th September 2012. The
main concerns voiced were over road safety. Whilst they recognise that the Council will
be taking advice on this matter, they would still wish their concerns to be formally noted.
Dunbeg Community Council also object on the basis that they were not consulted prior
to the application being submitted by either of the applicants. They note that the
proposed position of the roundabout is different from that shown on the local plan.
Further, subsequent to the application being submitted WHHA have addressed Dunbeg
Community Council and advised that the position of the proposed roundabout could yet
be moved from that shown on the plans. Dunbeg Community Council is concerned that
this could happen without consultation and would seek clarity on how the proposed
roundabout would affect traffic management at the existing entry to the village and the
current proposal for a second roundabout at the end of Kirk Road. Therefore, until
Dunbeg Community Council has been consulted further they cannot support the
application as it stands.
Page 179
Economic Development (25th February 2013) – the Council’s Transport Planner has no
concerns with the proposed roundabout.
Environmental Health Officer (28th February 2013) - no objection, subject to a
condition being attached to any grant of planning permission which secures a
construction method statement and their approval of said document.
____________________________________________________________________________
(E)
PUBLICITY:
Regulation 20 Advert, Local Application which expired on 30th August 2012
____________________________________________________________________________
(F)
REPRESENTATIONS:
At time of writing, a total of 62 representations have been received against this proposal.
Full details of representees are given at Appendix B. The grounds of objection may be
summarised as follows:
Development Plan Policy
•
The proposal is contrary to the approved/agreed development plan.
Comment: The proposal is located within Development Road Action 5/1 within the
adopted Argyll & Bute Local Plan and is consistent with the provisions of the
Development Plan.
Road Safety
•
Is this road not dangerous enough without adding to it? If road safety is not to be
compromised additional assessment by acknowledged experts in both traffic
behaviour and traffic management should be undertaken.
•
Tailbacks and the resulting congestion of the proposal, in such close proximity to
Pennyfuir Cottage’s ingress and egress, will compromise road safety.
•
There are already hazards on the road; traffic turning into the garage, the dark
coloured sign for Poppies, apparently invisible to some people, causing them to
brake at the last minute. Is another hazard to be a roundabout near a bad bend? If
the bad bend were straightened (slightly) as suggested, the visibility from Pennyfuir
cottage would not be adequate for a safe exit.
•
The Community Council meeting agreed that the preferred location for the
roundabout should be at the junction at Dunbeg Road End. This has been an
accident black spot for many years. With the possibility of a reduced speed limit
extending to Dunstaffnage Marina this will help in preventing future accidents.
Comment: Transport Scotland have responsibility for this trunk road and are therefore a
statutory consultee. In not raising objections to the proposal they will have had regard to
both the traffic engineering and road safety aspects of the proposal.
Removal of Rock
Page 180
•
What is the method to facilitate the removal of rock? The owners of the Halfway
Filling Station would be very concerned if any form of explosive blasting were to be
employed. Their premises are based on in-filled area. Vibration caused by the
blasting could cause disturbance to their foundations, buildings and more importantly
the fuel tank farm and associated pipe work. Disturbance to the latter infrastructure
is environmentally critical and they are very concerned about this aspect of the
proposal.
Comment: No details of intended working methods are available at this stage. This is a
matter which is proposed to be controlled by the construction method statement
condition and in consultation with the Environmental Health Officer and Transport
Scotland.
Location relative to Pennyfuir Cottage
•
The location is unsafe so close to The Cottage Halfway House (Pennyfuir Cottage).
We have lived in this cottage for over 20 years; this is the only dwelling on a 4 mile
stretch of the A85 between Saulmore Farm and Oban on our side of the road. We
do not understand the thinking behind this proposal and why our safety has been
over looked by the West Highland Housing Association on submission of this
proposal.
•
At this time Pennyfuir Cottage has a clear view of the road from both the left and
right and since the application of a non-skid surface at this location there have been
no accidents at all. The safety of my family will be put at risk by the addition of the
1500 vehicles your report states will be added to this A85 intersection. Making the
access to Pennyfuir Cottage a horrifying prospect, turning right/left going in/out by
car or on foot will mean dodging around slow moving traffic on Pennyfuir Cottage’s
side of the road and accelerating traffic on the other side, traffic could be backed up
from the roundabout preventing a car making a right turn into Pennyfuir Cottage’s
drive. Deliveries and pedestrian visitors to the Cottage will be put at risk and
pedestrian access to the cottage would at best be extremely dangerous.
•
The interests of the residents at Pennyfuir seem sacrificed for the big project. Apart
from the lack of consultation, the arrogance of the developer, the loss of privacy, the
noise and light pollution, it does seem that the gates of Pennyfuir Cottage would
have to be permanently open for access to be possible, its potential as a family
home will cease.
•
A portion of ground included in applicants’ plan, belongs to Pennyfuir Cottage.
Comment: Consultants on behalf the applicants have undertaken a ‘Stage 1 Road
Safety Audit’ which has been reviewed and accepted by Transport Scotland. The
relationship of the roundabout to the cottage in terms of road safety and residential
amenity has not attracted an adverse response from relevant consultees. The applicants
have stated in the ownership certificate accompanying this application that they are the
sole owners of all the land. Any dispute over land ownership between the applicants
and the owner of Pennyfuir Cottage would be a civil legal matter and not a material
planning consideration. .
Light Pollution
Page 181
•
Headlights from vehicles driving around the roundabout will flood Pennyfuir Cottage
and its garden with unwelcome light create flashing even strobe light effects across
the lounge and conservatory windows;
•
The street lighting on the roundabout will also illuminate Pennyfuir Cottage and its
garden as they will be less than 80yds away;
Comment: The Environmental Health Officer has no concerns regarding the effects of
street lighting or vehicle lights upon residential amenity.
Noise Pollution
•
Noise will be increased, large vehicles breaking as they slow down for the
roundabout with trailer wheels locking and accelerating vehicles on the other side of
the road.
Comment: The Environmental Health Officer has no concerns regarding noise upon
residential amenity.
Air Pollution
•
The smell of diesel fumes from queuing vehicles will be prevalent and a health
hazard.
Comment: The Environmental Health Officer has no concerns regarding air pollution or
the effect of odours upon residential amenity..
Visual Impact
•
There will be visual intrusion
Comment: There will be a degree of visual impact as a result of rock removal, the
roundabout itself and associated signage and lighting, however, taking into account the
fact that the proposal is to be located in the context of the existing trunk road corridor,
and the Environmental Health Officer has no concerns regarding light pollution, it is
considered that the visual impact will not be adverse.
Environmental Impact
•
If the proposed roundabout is in relation to a proposed development of a hotel and
chalet complex, the environmental impact of both the hotel and chalets along with
the new roads and a roundabout would be too great for the area.
Comment: The proposed site for the hotel and chalet complex is contained within a
Potential Development Area designated by the adopted Local Plan. Furthermore, the
environmental impact of any future proposals will be assessed through the planning
process. It is only the roundabout proposal which is currently being considered, albeit it
that it will facilitate a means of access to the Potential Development Area.
Alternative Location
•
Most people think the community will be best served with a roundabout at Dunbeg
road end which would be an alternative, more viable and probably cheaper location,
Page 182
and would serve the developments that have already taken place at Dunstaffnage
without the need to cross a cycle path, rather than to provide a roundabout at this
location to serve “future developments” which are not even at the planning stage.
Comment: The current location of the roundabout, as well as the existing access to
Dunbeg are both contained within the local plan designated Development Road Action
Area. However, in order to facilitate the development of land designated in the Local
Plan, the requirement for a second means of access has been identified by the
Transport Scotland and the Council’s Roads Engineers in order to cater for the scale of
development proposed at Dunbeg without adding inappropriate traffic volumes to Kirk
Road and in order to be able to ensure the availability of an alternative means of access
for emergency vehicles.
Adverse Impact on Local Businesses
•
The additional access road for Dunbeg off the proposed roundabout development
will significantly reduce the volume of traffic passing the Halfway Filling Station. Any
reduction in passing traffic volumes will result in a reduction in business levels at
these premises, with the attendant loss of local employment.
•
If customers feel or experience a negative aspect to accessing or leaving the
Halfway Filling Station it will deter their future patronage.
•
Business will be affected by the proposed roundabout diverting traffic. The shop/post
office and hairdressers are essential to the village.
Comment: Transport Scotland have not raised any concerns in terms of road safety
implications for vehicles accessing or leaving the garage. There are no policies within
the local plan which address the issue of the potential diversion of custom from
established businesses. Through traffic and persons not familiar with the area will still
continue to use the same route as they do at present. Local people will be familiar with
the location of established businesses and it is reasonable to expect that they will route
their journeys accordingly.
Impact on Core Path/Cycle path
•
The work carried out to the Core Path was tremendous and added an asset to the
community. We do not want our cycling path interfered with; this proposal will be
dangerous for the people using it. The cycle path away as that is the only place for
Dunbeg children and parents have to have a safe walk.
•
The road is the only development visible from the newly created Core cycle path. A
roundabout in the vicinity would not improve the character of the area and should not
be accepted. *the Land Reform Scotland Act 2003 requires every Scottish Local
Authority to produce a Core Paths Plan, which identify the most popular existing
routes in the area and will help to ensure the paths are protected from development
and obstruction in the future. If this is to be honoured then surely we cannot build a
roundabout, with the intent of connecting a double lane access road straight through
a very popular Core Path between Ganavan and Dunbeg. The overall impact on the
Core Path would be disastrous. This would totally distract from the relationship to
the surroundings encountered while enjoying the Core Path at the moment.
Page 183
Comment: The local plan provides for the establishment of a second means of vehicular
access to Dunbeg in order to serve the land identified for future residential development
at Dunbeg. Wherever this is routed it will involve need the existing cycle path to cross
the carriageway and appropriate safety measures wil need to be identified and put in
place at that time. This application is purely for the roundabout and implications for the
cycle path will need to be assessed at the time of a subsequent application for the
finalised road alignment.
Prematurity
•
We are some way off from requiring this roundabout. Why should we have a white
elephant sitting on the main route in and out of Oban? Invest more money at the
main entrance to the village of Dunbeg, and the developers Kirk road access to the
Science Park and houses.
•
The future WHHA development is on the opposite side of the A85. Why consider
such a major road construction which may not take place for many years, on the
wrong side of A85.
Comment: The roundabout is part of a key Development Road Action Area, which is
designated in the Local Plan and its provision is necessary to facilitate development
allocations on either side of the trunk road.
Related Development
•
Planning and approval for a family house in the grounds of the existing home
Pennyfuir Cottage has been granted;
•
The proposal for the developer is speculative, should Mr McCort get access to the
A85, it seems the woodland would be put on the market in the hope of selling as a
development for a future hotel;
•
The plans show sketches of a development for which no plans have been submitted.
The reality is a Mr Bill McCourt owns forestry, where a road has been allowed
without Planning removing tons of rock, to retrieve fallen trees. WHHA fail to show
where their road is to lead to, but choose to show a non-existing road with sketches
to “fantasy land”;
•
Recent changes to the village are of no advantage to its occupants. What may seem
advantageous on plans is actually of none to the villagers.
Comment: Recent development has been, and the future development at Dunbeg will
be, guided by the provisions of the approved development plan which provides for
significant residential development and a hotel/leisure element on either side of the trunk
road, which in turn, warrants the provision of a new junction in order to be able to
service the scale of development envisaged. The ownership of land and the motives of
the applicants’ are not material planning considerations. The details of any development
to be served by this junction will require to be the subject of separate planning
applications, which would need to be assessed on their respective merits.
Procedural matters
Page 184
•
Mr & Mrs Garside of Pennyfuir Cottage have stated that they have not received any
neighbourhood notification from Oban Council;
•
There has been insufficient consultation with the local community;
•
A public inquiry should be considered in order to discuss this along with other issues.
Comment: Neighbour notification was sent to: Pennyfuir Cottage, Dunbeg, Oban, PA37
1PX by the Central Validation Team on the 27th July 2012. There is no record of this
notice having been returned ‘undelivered’. The purpose of neighbour notification is to
alert those who will be most affected by the proposed development of their opportunity to
make representations to the planning authority regarding the application. Mr & Mrs
Garside have presented their case in writing in respect of this proposal, which has been
taken into account in determination of the application.
Given that the proposal does not amount to a ‘major application’ in terms of the
government’s planning hierarchy there is no requirement for formal community
consultation at the pre-application stage. Any consultation would be at the applicants’
discretion and the lack of consultation does not amount to a material planning
consideration.
Due to the level of representation which has been received it is recommended that a
Public Hearing be held.
NOTE: Committee Members, the applicant, agent and any other interested party should
note that the consultation responses and letters of representation referred to in this
report, have been summarised and that the full consultation response or letter of
representations are available on request. It should also be noted that the associated
drawings, application forms, consultations, other correspondence and all letters of
representations are available for viewing on the Council web site at www.argyllbute.gov.uk
____________________________________________________________________________
(G)
SUPPORTING INFORMATION
Has the application been the subject of:
(i)
Environmental Statement: No
(ii)
An appropriate assessment under the Conservation (Natural Habitats)
Regulations 1994: No
(iii)
A design or design/access statement: No
(iv)
A report on the impact of the proposed development eg. Retail impact,
transport impact, noise impact, flood risk, drainage impact etc:
•
Independent Stage 1 Road Safety Audit, November 2012
____________________________________________________________________________
(H)
PLANNING OBLIGATIONS
(i)
Is a Section 75 agreement required: No
Page 185
____________________________________________________________________________
(I)
Has a Direction been issued by Scottish Ministers in terms of Regulation 30, 31 or
32: No
____________________________________________________________________________
(J)
Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application
(i)
List of all Development Plan Policy considerations taken into account in
assessment of the application.
‘Argyll & Bute Structure Plan’ (2002)
Policy STRAT DC 2 – Development within the Countryside around Settlements
Policy STRAT SI 1 – Sustainable Development
‘Argyll & Bute Local Plan’ (2009)
Policy LP ENV 1 - Development Impact on the General Environment
Policy LP ENV 19 - Development Setting, Layout and Design
Policy LP SERV 2 - Sustainable Drainage Systems (SuDs)
Policy LP TRAN 1 - Public Access and Rights of Way
Policy LP TRAN 2 - Development and Public Transport Accessibility
Policy LP TRAN 3 - Special Needs Access Provision
Policy LP TRAN 4
New and Existing, Public Roads and Private Access
Regimes
APPENDIX A Sustainable Siting and Design Principles
APPENDIX F Allocations, Potential Development Area Schedules and Areas for
Action Schedules
Development Road Action 5/1 – strategic development road
Forthcoming Local Development Plan
As an emergent plan currently out to public consultation, the draft LDP has very
little material weight at this time. It should be noted however, that allocation of
the land for strategic road improvements (DRA 5/1) is proposed to be continued
in this plan in order to serve development land at Dunbeg.
(ii)
List of all other material planning considerations taken into account in the
assessment of the application, having due regard to Annex A of Circular
4/2009.
•
•
•
•
•
•
Scottish Planning Policy, advice and circulars;
the environmental impact of the proposal;
the design of the proposed development and its relationship to its
surroundings;
access, provision of infrastructure and planning history of the site and its
surroundings;
views of statutory and other consultees;
legitimate public concern or support expressed on relevant planning
matters.
Page 186
___________________________________________________________________________
(K)
Is the proposal a Schedule 2 Development not requiring an Environmental Impact
Assessment: Yes, in terms of Schedule 2 of the Environmental Impact Assessment
(Scotland) Regulations 2011 the proposal falls under category 10 (f) - Construction of
roads (unless included in Schedule 1), where the threshold for consideration of EIA is for
proposals where the area of work exceeds 1 hectare.
Where development might be schedule 2 development, the planning authority must
make a screening opinion, which is a decision whether or not EIA is required. In this
case, it has been concluded that no EIA is required.
This site an allocation in the current adopted Argyll & Bute Local Plan, which would have
been the subject of Strategic Environmental Assessment prior to its adoption; by virtue of
its nature, size and location the development is not likely to have any significant effects
on the environment; and, no part of the development is to be carried out in a “sensitive
area”
____________________________________________________________________________
(L)
Has the application been the subject of statutory pre-application consultation
(PAC): Not required.
____________________________________________________________________________
(M)
Has a sustainability check list been submitted: No
____________________________________________________________________________
(N)
Does the Council have an interest in the site: No
____________________________________________________________________________
(O)
Requirement for a hearing (PAN41 or other): Despite the local plan position, in view of
the number of representations which have been received and the range of issues raised,
which include matters of detail beyond matters of principle, it is recommended that
consideration is given to holding a discretionary local hearing prior to the determination
of the application.
____________________________________________________________________________
(P)
Assessment and summary of determining issues and material considerations
The proposal seeks permission for a roundabout on the A85 (T) at Dunbeg. The
application is submitted jointly by the prospective developers of land on either side of the
road which is identified in the plan for housing at Dunbeg and hotel/leisure development
at Tom Liath respectively (which will require to be the subject of separate planning
applications). The proposal comprises a four arm roundabout: a Westbound Arm (from
Connel); an Eastbound Arm (from Oban); a Northbound Arm (from Tom Liath); and a
Southbound Arm (from HIE Development). It also includes alterations to existing
footpaths and cycle path. The roundabout is part of a key Development Road Action
Area, which is designated in the Local Plan Development Road Action 5/1. Whilst the
site lies within this allocation it is also partially located within ‘Countryside Around
Settlements’ where in special cases, development of this nature, which will improve road
safety, provide economic benefits by facilitating access to adjoining allocations and
potential development areas, with a locational need and exceptional circumstances is
justified.
Page 187
With the exception of Dunbeg Community Council all Consultees are satisfied with the
proposal subject to the application of relevant planning conditions.
A total of 62 letters of representation have been received against this proposal along
with an objection by Dunbeg Community Council. A significant number of these relate to
the desirability or otherwise of establishing a second junction on the A85(T) at Dunbeg
(as making the existing Kirk Road junction the location for a roundabout), whilst more
localised concerns are raised by the occupiers of the closest dwelling to the proposed
site and the proprietors of the nearby filling station.
The principle of significant development at Dunbeg has already been established by the
current local plan and it is intended that these development aspirations will be rolled
forward into the emergent Local Development Plan, the draft of which is currently out to
public consultation. The identification of allocations and potential development areas at
Dunbeg have brought with them the expectation that a second means of access will
require to be established to serve prospective development on either side of the road, in
addition to the continued use of the existing junction at Kirk Road. Local Plan
Development Road Action 5/1 provides for such an approach.
Given its status as a trunk road, Transport Scotland are key in identifying the appropriate
location, layout and geometry of a roundabout to meet the identified needs. They are
content with the proposal in terms of its desirability, its positioning, its design and its
implication for traffic flow and road safety. The consenting of an appropriate roundabout
junction would be a key milestone in the bringing forth of associated proposals and
enabling the development of land on either side of the trunk road at Dunbeg.
____________________________________________________________________________
(Q)
Is the proposal consistent with the Development Plan: Yes
____________________________________________________________________________
(R)
Reasons why Planning Permission should be granted:
This site is allocated for strategic road improvements in the adopted ‘Argyll & Bute Local
Plan’. Whilst the site lies within this allocation it is also partially located within
‘Countryside Around Settlements’ where in special cases, development of this nature,
which will improve road safety, provide economic benefits by facilitating access to
adjoining allocations and potential development areas, with a locational need and
exceptional circumstances is justified. The detail of the development as proposed is
acceptable to the Trunk Roads Authority. All other material considerations have been
taken into account, including representations made by third parties, but these are not of
such weight as to indicate that the development plan should not be given the priority
which is accorded to it by statute.
____________________________________________________________________________
(S)
Reasoned justification for a departure to the provisions of the Development Plan
This proposal does not constitute a departure from the Development Plan.
____________________________________________________________________________
(T)
Need for notification to Scottish Ministers or Historic Scotland: None.
____________________________________________________________________________
Author of Report:
Arlene H Knox
Date: 07.03.2013
Page 188
Reviewing Officer:
Richard Kerr
Date: 10.03.2013
Angus Gilmour
Head of Planning and Regulatory Services
Page 189
CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 12/01520/PP
1.
The proposed development shall be carried out in accordance with the details
specified in the application form dated 11th July 2012; and the approved drawings
numbered: 1414-001 – Site Location Plan; 23A – Proposed Roundabout Planning
Boundary; 15B – Roundabout General Arrangement – Existing; 17D – Roundabout
General Arrangement – Proposed; and, 18D – Proposed Roundabout Capacity
Assessment; and stamped approved by Argyll and Bute Council.
Reason: In order to ensure that the proposed development is carried out in accordance with
the details submitted and the approved drawings.
2.
The proposed new roundabout junction on the A85 trunk road shall be constructed
to a layout and type (and method) of construction to be approved by Transport
Scotland, as the Trunk Roads Authority. (Note: The junction modifications will be
generally as detailed in RDA Construction Ltd drawing number 17 Revision D and
titled Roundabout GA - Proposed).
Reason: To ensure that the standard of access layout complies with the current standards
and that the safety of the traffic on the trunk road is not diminished
3.
The angle of repose of the finished rock face shall be as shown in the section on
drawing 17D and prior to the completion of the rock extraction operations details of
the treatment of the newly exposed rock face, including the approach to and the
means of dressing the rock face following primary rock modelling and measures to
establish vegetation, shall be submitted to and be approved in writing by the
Planning Authority, along with details of a mitigation monitoring plan relative to the
establishment of vegetation on the rock cut. The rock face shall be formed and the
vegetation established in accordance with the duly approved details.
Reason: In the interests of visual amenity in order to ensure that the finished rock cut
appears as natural as possible and allows colonisation by vegetation.
4.
That no works in connection with this permission hereby approved shall commence
unless a detailed site-specific construction method statement has been submitted to
and approved in writing by the planning authority in consultation with Transport
Scotland and the Environmental Health Officer. The construction method statement
shall include details of the measures proposed to deal with the removal of rock, and
reuse of rock on site. Once agreed, all construction works on site shall comply with
the approved construction method statement.
Reason: In the interests of public safety and the amenity of the area.
5.
No development shall take place until a landscaping scheme has been submitted to
and approved in writing by the Planning Authority in consultation with Transport
Scotland. The landscaping scheme, which shall comply with the Landscaping
recommendations of the Independent Stage 1 Road Safety Audit (November 2012)
shall include: a plan (at a scale of 1:500 or greater) showing a site appraisal
including contours (at 0.5 metre intervals), drainage characteristics, vegetation
patterns, significant site features, area of existing landscaping within the site, and
details of any to be retained, together with measures for their protection in the
course of development and shall indicate the siting, numbers, species and heights
(at the time of planting) of all trees, shrubs and hedges to be planted and to the
extent of any areas of earth mounding, cross sections and relationship to existing
Page 190
land form and the location of the site in its wider landscape context. The
development shall be landscaped and maintained in accordance with the approved
scheme as follows: (a) Completion of the scheme during the first planting season prior to the completion
of the development, or such other date as may be approved in writing with the
Planning Authority.
(b) The maintenance of the landscaped areas in perpetuity in accordance with the
detailed maintenance schedule/table. Any trees or shrubs removed, or which in the
opinion of the Planning Authority, are dying, being severely damaged or becoming
seriously diseased within three years of planting shall be replaced by trees or
shrubs of similar size and species to those originally required to be planted.
Reason: The proposed development and its location requires landscaping to fully integrate
the proposal with its surroundings.
6.
Prior to the commencement of development, the developer shall submit full working
details of the method of on-site disposal of surface water drainage. This shall be in
accordance with the CIRIA SUDS Manual for Scotland and Northern Ireland, to the
satisfaction of the Planning Authority in consultation with Transport Scotland.
Reason: To ensure the site is adequately drained to meet Best Management Practice and to
prevent pollution of watercourses.
NOTE TO APPLICANT
1.
The development hereby granted shall be begun on or before the expiration of three
years beginning with the date on which the planning permission is granted or deemed to
have been granted as provided for by Section 58 of the Town and Country Planning
(Scotland) Act 1997.
2.
Note: In terms of condition 2 above, the council can approve minor variations to the
approved plans in terms of Section 64 of the Town and Country Planning (Scotland) Act
1997 although no variations should be undertaken without obtaining the prior written
approval of the Planning Authority. If you wish to seek any minor variation of the
application, an application for a non-material amendment (NMA) should be made in
writing to Planning Services, Whitegates Offices, Whitegates Road, Lochgilphead, PA31
8ST. It should be noted that only the original applicant can apply for an NMA under the
terms of Section 64 of the Town and Country Planning (Scotland) Act 1997. Any
amendments deemed by the Council to be material, would require the submission of a
further application for planning permission.
3.
Whilst this permission authorises the removal of rock and other material required for the
formation of the roundabout in accordance with the approved plans, this permission
should not be taken to imply any consent for the deposition of material for the purposes
of land-raising, access road formation or any other purpose, on land either within, or
beyond the confines of, the application site. Dependent upon the intended use of any
material extracted from the site in connection with the development hereby permitted,
further planning permission is likely to be required, and the applicants are advised to
establish whether such consent is needed before any engineering operations are
commenced on this site.
Page 191
4.
The road will necessitate a Minute of Agreement between Transport Scotland and the
Applicant prior to commencement. This Minute of Agreement contains details of the
conditions that the Applicant will require to adhere to, as the completed works are to be
incorporated as part of the trunk road. Applicants are advised to allow sufficient time for
the drafting of the Minute of Agreement and Approval of the construction drawings,
which require to be submitted to Transport Scotland well in advance of the start of works
on site. Applicants should note that the Minute of Agreement contains a mechanism to
allow the recovery of all reasonable costs incurred by Transport Scotland as a result of
the works on the trunk road. It is a requirement that the works will meet the standards
contained in the Design Manual for Roads and Bridges.
Page 192
APPENDIX A – RELATIVE TO APPLICATION NUMBER: 12/01520/PP
PLANNING LAND USE AND POLICY ASSESSMENT
A.
Settlement Strategy
This site is allocated in the current ‘Argyll & Bute Local Plan’ as part of ‘Development
Road Action 5/1’. The nature of the action required is detailed as a ‘strategic
development road’ to facilitate housing, business, and community facility development at
Dunbeg. Whilst the site lies within this allocation it is also partially located within
‘Countryside Around Settlements’ where in special cases, development of this nature,
which will improve road safety, provide economic benefits by facilitating access to
adjoining allocations and potential development areas, with a locational need and
exceptional circumstances is justified.
In accordance with the Town and Country Planning (Scotland) Act 1997 when
determining a planning application the planning authority are required to make the
determination in accordance with the provision of the Development Plan unless material
considerations indicate otherwise. The adopted ‘Argyll & Bute Local Plan’ allocation is
therefore the key material consideration in the determination of this case.
Having due regard to the above it is considered that the proposal is consistent
with Policy STRAT DC 2 – Development Within Countryside Around Settlements of
the Argyll & Bute Structure Plan (approved 2002) and Appendix F: Allocations,
Potential Development Area Schedules and Areas for Action Schedules of the
adopted ‘Argyll & Bute Local Plan’ (2009)
B.
Location, Nature and Design of Proposed Development
The proposal is located on the A85 (T) to the south of the village of Dunbeg. The closest
properties are the dwellinghouse Pennyfuir Cottage, which is located immediately
adjacent to the north eastern part of the red line site boundary and the Halfway Filling
Station, which is located approximately 40 metres beyond the north eastern part of the
red line site boundary. The A85 trunk road is the strategic link between Perth and Oban
and is subject to the national speed limit. At present the road presently skirts round a
rocky knoll and is the subject of quite a bad bend.
The proposed roundabout is part of the way forward to being able to release long-term
development land to the west of the A85 (T) at Dunbeg by providing a secondary means
of access to the village of Dunbeg; and also access a Potential Development Area to the
east of the A85. Transport Scotland have indicated that in order for the roundabout to be
acceptable to them they would also require a ‘gateway feature’ in the form of
signage/pillars constructed to the north end of Dunbeg in advance of the Kirk Road
junction, to compliment the new roundabout.
The proposal comprises a four arm roundabout providing access to land on either side of
the road and entails the slewing of the existing road alignment in order to improve the
alignment of the main carriageway.
A rock face to a height of approximately 18 metres above road level, with an angle of
repose of 55 degrees is required to be excavated to the south. There will be a drainage
ditch at the base of the excavated rock face. There will be a footpath running along the
eastern side of the site. There is no change in level indicated to the north and west of the
proposed roundabout. To the west of the roundabout the existing footway is to be
Page 193
retained, and the area of the existing carriageway which is to become redundant is
proposed to be denoted as a cycleway. Post and wire fencing is proposed to enclose
the site
Several areas around the new roundabout are to be landscaped. Some of these areas
are located within the visibility envelopes of the approaches and also on the central hub.
No details of the type of landscaping proposed have been provided. All that is
delineated on the plans at present are the proposed grassed areas. It is recommended
in the Stage 1 Safety Audit that, preferably the areas within the visibility envelopes
should be hard surfaced; if this is not desirable or possible then the choice of
landscaping should be grass with low maintenance characteristics or a species with a
low mature height and low maintenance characteristics. A landscaping condition is
recommended to address this issue.
The redundant section of the carriageway of the current alignment of the A85 (T) is to be
retained and used as a cycleway. There is potential for drivers on the trunk road, who
will be able to see the redundant carriageway, may be confused about the route they
should follow. The Stage 1 Safety Audit recommends that some form of landscape
bund/grassed area and planting be provided at the end of the existing carriageways
which are to become disused in order to mask the see through from the approaches
onto the redundant carriageway from the new carriageway. A landscaping condition is
recommended to address this issue.
To ensure the newly exposed rock face has as natural an appearance as possible, care
will need to be taken with its treatment. A condition is therefore recommended to
ensure that the exposed rock face is modelled and dressed as sensitively as possible.
It has been confirmed that all drainage shall be designed in accordance with the CIRIA
SUDS Manual and is to drain to the existing watercourse adjacent to the A85. A
condition has been recommended in this regard.
Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policies LP ENV 1 - Development Impact on the General
Environment; LP ENV 19 - Development Setting, Layout and Design; LP SERV 2 Sustainable Drainage Systems (SuDs) and APPENDIX A - Sustainable Siting and
Design Principles of the Argyll & Bute Local Plan (adopted 2009)
C.
Landscape Character and Visual Amenity
As this proposal will be located within an existing Trunk Road Corridor, outwith any
landscape designations within a Development Road Action Area, and given that the
works are relatively localised in nature, it is considered that it will not have any significant
adverse impact on landscape character or visual amenity.
Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy ENV 1 – Development Impact on the General
Environment of the Argyll & Bute Local Plan (adopted 2009).
D.
Impact on Access to Countryside.
The Council’s Transport Planner and Access Manager have confirmed that there are no
Core Paths in this area; consequently the proposal will not have any adverse impact on
access to the countryside.
Page 194
Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policy LP ENV 1 (B) - Development Impact on the General
Environment
E.
Road Network, Parking and Associated Transport Matters.
The Council’s Transport Planner has no concerns with this proposal, and has confirmed
that: the off-road cycle track linking Ganavan and Dunbeg which forms part of the
National Cycle Network route 78, is set well back from the road corridor and, as such,
would not be affected by this proposal.
The Council’s Transport Planner further advises that the footway along the A85 is not
designated as shared use and, as such, should not be used by cyclists however he
understands that some cyclists do currently use the pavement and the police think that
this is favourable to the road due to traffic volumes, speeds and visibility. Furthermore,
that Transport Scotland have recently confirmed that they will not re-designate the
footway as shared use as it is too narrow.
Transport Scotland have confirmed that they have no objections to the proposal subject
to a condition which ensures that the proposed new roundabout junction on the A85
trunk road is constructed to a layout and type (and method) of construction to be
approved by Transport Scotland, as the Trunk Roads Authority. Transport Scotland also
wish it to be noted that the junction modifications will be generally as detailed in RDA
Construction Ltd drawing number 17 Revision D and titled Roundabout GA - Proposed).
The reason for the condition recommended by Transport Scotland is to ensure that the
standard of access layout complies with the current standards and that the safety of the
traffic on the trunk road is not diminished
Having due regard to the above it is considered that the proposal is consistent
with the provisions of Policies LP TRAN 1 - Public Access and Rights of Way; LP
TRAN 2 - Development and Public Transport Accessibility; LP TRAN 3 - Special
Needs Access Provision, and LP TRAN 4 New and Existing, Public Roads and
Private Access Regimes of the Argyll & Bute Local Plan (adopted 2009).
F.
Noise, Light & Air Pollution
The existing road network is unlit. The Design Manual for Roads and Bridges provides
the mandatory requirement that the new roundabout must be provided with a system of
street lights in the interests of road safety.
Noise, light and air pollution have been raised as matters of concern for the occupiers of
Pennyfuir Cottage, which is the closest property to the proposed roundabout.
Environmental Health officers have taken these concerns into account and have advised
that they do not have concerns about the impact of the proposal on residential amenity.
Having due regard to the above it is considered that the proposal is acceptable.
G.
Blasting & Rock Face Protection
Rock excavation is required to allow construction of the roundabout and access road.
As such, steep exposed rock faces will most probably be constructed adjacent to the
carriageway. Whilst the manner in which rock will be excavated and the condition of the
excavated rock face is as yet unknown, the risks arising from future rock falls must be
Page 195
considered. Consideration requires to be given to the long term stability of the exposed
rock face and the need to provide widened verges, rock ditches, berms or rock fences to
minimise the risks arising to road users from rock falls. Agreement in respect of these
works will require to be obtained in advance from Transport Scotland given the proximity
of the works required to the trunk road. The method of rock removal will be dictated by
local conditions and there is no certainty that rock blasting will be necessary.
In light of the concerns raised by the Halfway Filling Station regarding ‘blasting’ and the
proximity of Pennyfuir Cottage, Development and Infrastructure has sought clarification
from the applicant.
If required, rock excavation works would be carried out by a combination of excavator
mounted hydraulic breakers and blasting. All blasting would be carried out by specialist
drilling and blasting contractors, qualified and experienced in blast design. All blasts
would be designed in order to minimise ground vibration with delays being introduced
between each charge, 95% of blasts will require to conform to a maximum vibration limit
of 6mm/second measured at the nearest property approximately 100m distant, with an
absolute maximum level of 12mm/second. The limit at which structural damage may
occur is normally in the 25-30mm/second range.
It is recognised that specific concerns have been expressed in relation to the effect of
blasting on underground fuel storage tanks. In the opinion of advisors to the applicant,
provided that blasts are designed to maintain vibration limits at the nearest property as
specified above, and given that the tanks are approximately three times the distance
from the closest rock excavation area, they would not anticipate vibration of any
significance at the filling station. Using the reduction over distance expected as above,
even if there was an occasion where the absolute maximum 12mm/sec. limit was
reached at the nearest property, the vibration at the filling station could be expected to
be in the region of 4mm/sec.
In light of recent experience in relation to blasting close to properties it can reasonably
be expected that by careful planning and blast design, vibration levels can be controlled
to an acceptable level which will not have a detrimental effect either on Pennyfuir
Cottage or the filling station. In addition a small test blast would be carried out and
monitored to make certain that the mitigation measures described are producing the
desired effect.
It is recommended that a condition is attached to any grant of planning permission to
secure and approve the exact method of dealing with the rock.
Having due to the above it is considered that the proposal is acceptable in this
regard.
H.
Infrastructure
It is proposed to connect the development to the public drainage network. Scottish
Water has confirmed that they have no objection to the proposal. A detailed drainage
layout is not available at this stage. It is noted that all drainage is to drain to the existing
watercourse at the side of the A85 (T).
Having due regard to the above it is considered that the proposal consistent with
the provisions of Policy LP SERV 1 – Private Sewage Treatment Plants and
Wastewater (i.e. drainage) Systems.
Page 196
APPENDIX B – REPRESENTATIONS RELATIVE TO APPLICATION NUMBER: 12/01520/PP
AGAINST THE PROPOSAL
Grace Forbes
1 Campbell Street
Oban
PA34 4BQ
27/09/2012
O
Glenda Critchley
1 Iola Cottages
Appin
Argyll
PA38 4BA
19/09/2012
O
Jean McIver
1 Kilchurn Place
Oban
Argyll
24/08/2012
O
Alison Lamont
11 Camus Road
Dunbeg
PA37 1QD
24/08/2012
O
S MacDonald
11 Meadow Road
Dunbeg
Oban
PA37 1QB
19/09/2012
O
Mrs Carol Francis
12 Polvinister Gardens
Oban
Argyll
PA34 5TA
19/09/2012
O
A Black
13 Etive Road
Dunbeg
Oban
PA35 QF
19/09/2012
O
Ms Marie Archer
16 Camus Road
Dunbeg
Oban
PA37 1PD
27/09/2012
O
C M G Hunter
17 Castle Road
Dunbeg
Oban
Argyll And Bute
PA37 1QH
20/09/2012
O
Page 197
Charlie Hunter
17 Castle Road
Dunbeg
Oban
Argyll And Bute
PA37 1QH
19/09/2012
O
H Morrison
18 Lochnell Road
Dunbeg
Oban
PA37 1QJ
24/08/2012
O
Mrs Jean Morrison
18 Lochnell Road
Dunbeg
Oban
PA37 1QJ
24/08/2012
O
D Porter
19 Longsdale Crescent
Oban
Argyll And Bute
PA34 5JP
19/09/2012
O
Frances Grant
2 Adelphi Villa
Nursery Lane
Oban
Argyll
PA34 5JA
19/09/2012
O
F Twort
2 Keil Gardens
Benderloch
By Oban
PA37 1JY
20/09/2012
O
M MacKinnon
2 Meadow Road
Dunbeg
Oban
PA37 1QB
20/09/2012
O
Glynis Dewar
2 Underwood
Longistan Road
Oban
PA34 5JW
27/09/2012
O
Mr W MacDougall
27 Camus Road
Dunbeg
Oban
PA37 1QD
19/09/2012
O
The Owner/Occupier
3 Moss Park
North Connel
PA37 1TD
20/09/2012
O
Kim Miller
34 Lochnell Road
Dunbeg
19/09/2012
O
Page 198
Oban
PA37 1QJ
Margaret MacDonald
46 Lochnell Road
Dunbeg
Oban
Argyll
19/09/2012
O
Mr Neil MacEachan
48 Lochnell Road
Dunbeg
Oban
PA37 1QJ
17/09/2012
O
Mr Neil MacEachan
48 Lochnell Road
Dunbeg
Oban
Argyll
23/08/2012
O
Mrs Lesley Fraser
49 Lochnell Road
Dunbeg
Oban
PA37 1QJ
23/08/2012
O
K Lang
5 Kirk Road
Dunbeg
Oban
PA37 1TP
17/09/2012
O
Allan Lockhart
53 Lochnell Road
Oban
Argyll
19/09/2012
O
Carolyn Seggie
54 Lochnell Road
Dunbeg
Oban
Argyll
PA37 1QS
19/09/2012
O
R Morrison
6 Nelson Road
Oban
Argyll
PA34 4DQ
24/08/2012
O
Jenny McLeod
63 Lorn Road
Dubeg
Oban
PA31 1QQ
20/09/2012
O
Susan McKinlay
7 Breadalbane Mews
Breadalbane Street
Oban
Argyll
PA34 5PD
19/09/2012
O
Page 199
Avril Lamont
9 Hillside
Dunbeg
Oban
PA37 1QL
17/09/2012
O
Wilma MacLean
9A Millpark Terrace
Oban
Argyll
PA34 4JH
19/09/2012
O
Mrs K T MacLean
Achuil
Barcaldine
Oban
Argyll
PA37 1SG
19/09/2012
O
W Sharples
Ardgorm
North Connel
PA37 1RW
27/09/2012
O
L Smtih
Aureol
Main Street
Connel PA37 1PA
20/09/2012
O
C/o Mr Allan MacAskill
5 Ferryfield Road
Connel
PA37 1SR
27/08/2012
O
Val J Brown
Carraigmhor
Benderloch
PA37 1RT
24/08/2012
O
K F Eaton
Dalfuar
Barcaldine
By Oban
PA37 1SF
27/09/2012
O
Mrs M J Eaton
Dalfuar
Barcaldine
By Oban
PA37 1SF
27/09/2012
O
I Henry
Dun Fraoich
Pulpit Hill
Oban
PA34 4LZ
19/09/2012
O
Susan Henry
Dun Fraoich
Pulpit Rock
Oban
19/09/2012
O
Mr And Mrs Derek
Garside
Page 200
PA34 4LZ
Alison Dawson
Dunaltsa
Main Street
Connel
PA37 1PA
27/09/2012
O
Angela McDougall
Etive Awe
Lochandhu Road
Taynuilt
Argyll
PA35 1JQ
19/09/2012
O
Halfway Filling Station
Dunbeg
Oban
Argyll And Bute
PA37 1PX
02/10/2012
O
Colin Paterson
Innishewen
Connel
By Oban
PA37 1PT
20/09/2012
O
A J Summers
Jane Road
Dunbeg
Oban
19/09/2012
O
L MacDonald
Lairfad
Ardfern
By Oban
Argyll
PA31 8JA
24/08/2012
O
J Hamilton
Loch Na Beithe
North Connel
Argyll
PA37 1QX
20/09/2012
O
Gillian Glasgow
Lochnell Road
Dunbeg
Oban
Argyll
19/09/2012
O
Mrs W Lewis
Mo Dhaichaidh
Airds
Taynuilt
PA35 1JW
19/09/2012
O
J Garside
Pennyfuir Cottage
Halfway House
Dunbeg
19/09/2012
O
A Black (Benderloch)
Ltd
Page 201
Oban
Derek Garside
Pennyfuir Cottage
Halfway House
Dunbeg
Oban
PA37 1PX
19/09/2012
O
Carol Garside
Pennyfuir Cottage
Halfway House
Oban
PA37 1PX
19/09/2012
O
Fiona Hunter
Rosebank
Appin
Argyll
PA38 4BL
15/08/2012
O
Jan Smith
Stable Cottage
Benderloch
By Oban
PA37 1QU
20/09/2012
O
The Owner/Occupier
The Bungalow
Tynribbie
Appin
Argyll
PA38 4DB
20/09/2012
O
Mrs C M Webster
The Falls Of Lora Hotel
Connel
By Oban
PA37 1PB
19/09/2012
O
D H Brown
The Machair
Lower Vaul
Scarnish
Isle Of Tiree
20/09/2012
O
Donalda Henderson
Tigh Na Fuaran
Taynuilt
Argyll
19/09/2012
O
S Coates
Tigh Na Sith
Barran
Kilmore
Oban
PA34 4XR
24/08/2012
O
L McNiven
Toriskay
Rowan Road
Oban
PA35 5TY
19/09/2012
O
Page 202
The Owner/Occupier
Walden
Glenmore Road
Oban
Argyll
PA34 4PG
20/09/2012
O
Page 203
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NOT FOR PUBLICATION by virtue of paragraph(s) 13
of Schedule 7A of the Local Government(Scotland) Act 1973
Document is Restricted
Agenda Item 8
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NOT FOR PUBLICATION by virtue of paragraph(s) 13
of Schedule 7A of the Local Government(Scotland) Act 1973
Document is Restricted
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