• Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust
  • Community of Arran Seabed Trust

COAST objects new salmon farm in North Kilbrannan MCFF

Read here COAST's objection to Marine Harvest’s latest application to site a Salmon Fish Farm at Rubha Riabhach on the Northern entrance to Cour Bay, which they refer to as North Kilbrannan.

SEPA Registry
Grasser House
Fodderty Way
Dingwall
IV15 9XB


Dear SEPA

Re: OBJECTION TO APPLICATION CAR/L/1168182 - NORTH KILBRANNAN MCFF

We are writing to object to Marine Harvest’s latest application to site a Salmon Fish Farm at Rubha Riabhach on the Northern entrance to Cour Bay, which they refer to as North Kilbrannan, and to request that SEPA reject the application.

  • SEPA’s Duty

In our view SEPA has a legally binding duty to protect and enhance biodiversity, in common with all Scottish public bodies, and that it would be failing in this duty if it gives consent for a fish farm biomass that has a high risk of cumulative impact on wild salmonids through sea lice, disease and escapes. SEPA used to accept this responsibility and that while it does not do so currently, it is widely expected that its duty to do so may be reinforced after the RECC Committee’s ongoing parliamentary inquiry reports on the subject.

We understand that the CEO of SEPA has written to Mr Dey of the ECCLRC, to explain that SEPA wants new, larger fish farms to be located, 'in exposed, dispersive environments…', because the strong tides in such exposed locations mean that, '… the risks of disease and, hence, medicine usage, are also likely to be lower.' '…in practice, large farms would be limited to more exposed locations where the risk of infection with sea lice and other diseases can be less'. This would seem to be a strong argument against Marine Harvest’s application to site another large fish farm in the Kilbrannan Sound which is not a dispersive environment and where the current cumulative environmental impact is unknown.

  • SEPA’s Risk Assessment For This Site.

We note SEPA’s own risk assessment for this site indicates that the discharge of effluent from the fish farm is likely to impact significantly on the water quality by: Increasing the level of nutrients in the water column; increase deposition of organic matter from fish feed and faeces on the seabed; introduce potential toxic effects of medicines and other chemicals on the fauna and flora of both the water column and seabed and may affect the interests of other water users and designated conservation interests. We agree with SEPA on your assessment of all these risks, that the risks are high and therefore SEPA should not issue a licence.

  • Impact on Wild Salmon Migration and Heritable Fishing Rights.

Rubha Riabhach is a significant waypoint on a wild salmon migration route as proved by the very productive netting station that is traditional sited there (currently dormant for conservation reasons). Marine Harvest wish to place their fish farm on the dormant netting station site which would obstruct and pollute the migration route of salmon heading for Loch Fyne and the Clyde with sea lice, chemical and effluent pollution. Wild salmon use coastal areas on migration to and away from their rivers, and sea trout are there year-round, particularly in areas like Cour Bay and the mouth of the Crossaig Burn. The increased risk to these Priority Marine Feature species, caused by escapes of farmed fish in these areas threaten wild salmonids, as made clear by the SAMS report.

  • Impact on the Crustacean Fishery.

Rubha Riabhach is the primary breeding ground for lobsters on this stretch of coast which is fished by commercial creel fishermen and residents. We note that Marine Harvest will be dependent on the use of emamectin benzoate (Slice,) which is proven to be very harmful to crustaceans. Marine Harvest’s modelled footprint gives Allowable Zone of Effect distances (which we understand to mean the area within which it is permitted for much seabed life to be killed) of 474 m and 483 m along Transects T1 and T2 respectively, so the affected area covers the entire lobster breeding ground. We further understand that under weak dispersal conditions at Rubha Riabhach the use of Slice will create a concentration of chemicals lethal to crustaceans that exceeds Environmental Quality Standards by 1000% and under full-flow conditions it will still exceed permissible standards by 400%.

The proposed mitigation method of an enhanced monitoring regime will be ineffective because the usual method of grab sampling employs grabs that are too small to catch large crustaceans and do not work on hard substrates. According to the Scottish Aquaculture Research Forum 098, a 50% average reduction in the diversity of crustaceans was correlated with the use of emamectin benzoate on adjacent fish farms in Shetland. It would seem therefore, that the proposed fish farm will kill off entirely an important natural breeding ground for lobsters. Marine Harvest’s own survey report fails to make any mention at all of the European lobster (Homarus gammarus,), which local creelers catch regularly and therefore their work is must to be challenged by SEPA with regard to its accuracy and thoroughness.

The potential impact on the health of the Nephrops and the brown crab commercial fishing and health of the stock is also unknown and therefore can be considered at risk. This is an unacceptable risk of impact to the crustacean fishery and the ecosystem and SEPA should reject the application.

  • Flawed Modelling of an Inappropriate Site Marine Harvest have applied for a maximum production of 3,611 tonnes per year, which would make this one of the largest fish farms in Scotland. At present the maximum production allowed is 2500 tonnes unless ‘Newdepomod’ has been used to model a larger quantity, which it has not. But even if it had, SEPA’s CEO has stated to the Parliamentary Inquiry that larger fish farms may be permitted in future, but very large fish farms should be sited in dispersive environments with strong tidal flows where their pollution and effluent will do less harm. Kilbrannan Sound is an estuary with relatively weak tidal flow, as shown by Marine Harvest’s own modelling dat. The modelling also shows that emamectin benzoate levels would already exceed Environmental Quality Standards by between 400 and 1000% calculated at 2500 tonnes of biomass rather than the maximum of 3,611 tonnes of biomass. Therefore, this application exceeds the permitted levels (even when based on the 2500 tonne modelling which underestimates the biomass and does not account for the maximum biomass applied for) and is not suitable for this location. It would seem that Marine Harvest’s data is subject to omissions and errors and the parts that are accurate show that the application is non-compliant. In this case a license should not be granted as this site is wholly unsuitable and there is a high risk of damaging, cumulative environmental impact.

  • Cumulative Impact from Other Fish Farms. Marine Harvest wish to apply for Carradale North and South to expand to 3500 tonnes, so all the arguments in the paragraph above about grossly exceeding permitted levels for an estuary like the Kilbrannan Sound apply to those applications as well. We also understand that In some cases SEPA require hydrodynamic modelling to assess the larger scale deposition of suspended organic material and we believe that SEPA should be considering whether there may be cumulative effects of having more than 10,000 tonnes of salmon in the same area. We understand that Newdepomod cannot measure this effect, so hydrodynamic modelling would appear to be required in this case and we can find no evidence that it has been stipulated as a requirement, which we consider to be a serious omission. The modelling report states that the mass of solids released per year was estimated to be 1,012,903 kg ie 1000 tonnes of fish faeces and Form C estimates using 6,325 tonnes of fish food a year, very alarming figures which are likely to draw very critical public comment. Marine Harvest have also declared their intention to develop a new shorebase which could include staff facilities and net washing facilities near to the proposed site. If so, it raises the question of where the additional pollution from this facility will go and the presumption must be into the sea, which has not so far been accounted for under the additional cumulative effect.

  • Noise and Light Pollution. The noise of the existing Carradale fish farms is heard all across the water to Arran and is a constant presence for residents and visiting tourists. Expansion of these farms and the presence of this new farm will further degrade the quality of life for the people of Arran. The presence of a generator and lights running permanently just off the coast combined with regular working activity will create a disproportionate intrusion into the existing peace of the area and completely change its character.

  • Visual Impact from North Arran. The proposed fish farm cages will be in full view from the mountains and hills of north Arran and their visual impact will add to the existing impact experienced by the presence of the North and South Carradale fish farms. These farms already have a negative effect on the experience of hill walking tourists visiting Arran and a new farm will amplify this and has the potential to negatively impact the hillwalking tourism industry on which Arran depends to sustain its year round tourist revenue.

Yours sincerely,

Paul Chandler; Director COAST