Lamlash Fish Farm: A Message from COAST

Thanks to everyone who attended the COAST public meetings where we discussed and explored our community’s opinions on the Scottish Salmon Company’s (SSC) proposal to double the production of salmon in the waters of Lamlash Bay and potential development at other sites.

As promised, we’d like to share with you:

How you can help
A summary and key messages from the six public meetings, attended by 160 people from 13 different villages
The process and steps COAST is taking

1. HOW YOU CAN HELP
Email Councillor Tom Marshall, Chair of NAC Planning Committee tommarshall@north-ayrshire.gov.uk and copy in James Miller, Head of NAC Planning jamesmiller@north-ayrshire.gov.uk
to “invite and consider public comments to inform the scoping opinion and other steps of the planning process/ Environmental Impact Assessment” (We have attached at the end below a form of words that you can adapt)

Or by post to:

Clr.Tom Marshall
Haus Saron,
106 Greenock Road,
Largs,
KA30 8PG

Mr James Millar
North Ayrshire Council,
Planning Department,
Cunninghame House,
Irvine,
KA12 8EE

You can also contact other NAC Councillors here.

Join our Clean Sea Water Action Group

If you have time and energy to help us with this campaign please respond to this email and let us know. We will have a first meeting of the group in January to discuss further action, i.e. how and when to use the petition signatures

Help us spread the word

Many people on Arran and visitors are unaware of this issue. Please help us raise awareness by sending out the leaflet we produced.
You can also share news and information about the impact of salmon farms through social media. We are on Facebook and Twitter.
The video we showed at the meeting is here in case you would like to share that too.
More information can be found on our website. Give us a call if you need anything or you have any questions visit our website.

2. SUMMARY OF COMMUNITY VIEWS/ SUGGESTIONS

There is considerable alarm about the application the Scottish Salmon Farm are putting in for Lamlash Bay, but also about the company’s interest in setting up salmon cages in the “wider Arran area”.

Arran wants a sustainable economy. We should not allow industry to “kill Arran’s golden goose, our environment”, “We want a beautiful, clean, unpolluted sea for locals and tourists to enjoy”. The Arran brand is a “clean, quality” brand, we should “encourage small scale organic aquaculture” (ie: mussels, oysters or scallops). Many attendees also suggested closed containment systems, on land, should replace open net cages.

There are deep concerns about the risk that salmon sewage, organic and chemical, poses to our health and to our protected wildlife. “Why isn’t SEPA testing water quality?” was a question that kept coming up. Villagers want to know if kids jumping off the pier, swimmers and kayakers are safe. The air blown inland may also be polluted with “neurotoxins used to deal with salmon sea lice which can affect human’s respiratory system and eyes” as well as impacting bees and other land- based wildlife. “We have no longitudinal studies on crabs, lobsters or shell fish within a mile of a fish farm. I fear that only when we find neurotoxins in the fish on the table will there be action on this”. There are also concerns about animal welfare and unregulated wrasse fisheries.

Participants could not understand how the same Scottish government that recognised in 2016 how special Arran’s waters and seabeds are – by enforcing a Marine Protected Area with seagrass meadows and maerl beds – could be considering to allow 1000 tons of salmon sewage including toxic chemicals to go into Lamlash Bay, untreated. Many participants were of the opinion that “They should close open water salmon cages in Arran’s waters unless they can demonstrate that the toxic effects on the environment will be prevented”.
The lack of consultation, the company’s poor environmental performance and no access to information about their operations and impact locally all aggravate the situation. The community does not trust the company or the government and has a clear message: “Arran’s seas are not for sale”.

3. THE PROCESS AND STEPS COAST IS TAKING

In August 2017, the Scottish Salmon Company (SSC) withdrew an application from 2015 to expand the Lamlash Bay salmon farm by 60%. This application, strongly opposed by COAST and many individuals and groups from Arran – you may remember the demo out at sea in December 2016 – was called in by Cabinet Secretary Roseanna Cunningham. There was about to be a hearing in parliament following a governmental independent assessment just when they withdrew the application.

Before a month had gone by, the SSC informed COAST and other community members that they are going to propose a new, more ambitious, application to double their production in Lamlash Bay. The SSC asked COAST for a private meeting, we responded we would be happy to meet them, but in a public, open, meeting.

This proposal was met with disbelief from the community. Because of its larger scale it requires planning permission and potentially an Environmental Impact Assessment (EIA) from North Ayrshire Council (NAC) as well as a CAR licence by the Scottish Environment Protection Agency (SEPA). It is a complicated procedure and COAST are engaging with a volunteer EIA expert and lawyers to understand how we can stop this development.

In the meantime, COAST has been carrying out research, getting in touch with other affected communities to join forces and sharing the information we have with the local newspaper, our local politicians and the public. We have enabled a wide community discussion through six public meetings around Arran to learn how the community on Arran consider aquaculture should or shouldn’t be developed locally.

We have had correspondence with a senior planner from North Ayrshire Council, who may be responsible for this planning case. He has written and informed us that NAC cannot consider COAST a community consultee or ask for public opinion to inform their screening and scoping opinion in response to the SSC’s request because the regulations do not allow this. We have a different opinion on this as public and NGO opinion can and are taken into account at a local authority’s discretion. In fact the Planning Officers Society guidelines state ‘Where a formal Scoping Opinion is sought from a Local Planning Authority, it is mandatory for the authority to consult the statutory consultees. It is usually good practice to include relevant non-statutory consultees.’

Once the SSC submits the screening/scoping request, NAC has to respond in 21 days as whether an EIA is required or not and 35 days as to the scope of the EIA required. Because the council is not legally required to consult with the public at this stage and the short turnaround time, COAST has been informed it will not be consulted directly at this stage or indeed the later stages.

We are concerned that the company may not submit all the environmental, social and economic impacts of this expansion and that NAC may or may not have the expertise to assess the company’s screening and scoping report. This is why we are asking you to write to the council’s Head of Planning AND Councillors to ensure the people of Arran can feed into this process with their opinions and ideas. Please support us in being acknowledged as a non-statutory consultee by taking the action of emailing or writing to Clr Tom Marshall as described above.

SEPA has an obligation to consult the public prior to giving the licence. We will inform you as soon as the consultation is open. It should be announced in the Arran Banner and will be visible here: https://www.sepa.org.uk/regulations/consultations/advertised-applications-under-car/.

If the application were to be given planning permission and CAR license, we would ask the cabinet secretary Roseanna Cunningham to call it in as she did with the previous one.

Thank you again for your time and support, and please get in touch if you have any questions.

The COAST team

COAST (Community of Arran Seabed Trust)
Old Pavilion, Lamlash, Isle of Arran, KA27 8LS
Tel: 01770 600656

A form of words that you can adapt

Dear Councillor Tom Marshall
Re: Proposed Screening and Scoping Request and Planning Application by the Scottish Salmon Company; Fish Farm Expansion, Lamlash Bay, Isle of Arran
I am a resident of Arran and I write to you as Chair of the Planning Committee of Arran and North Ayrshire with regard to the proposed application for a screening/scoping request and planning application by the Scottish Salmon Company (SSC), in Lamlash Bay, Arran. The SSC has stated publicly that they will be submitting a new planning application to double the size of the St Molios fish farm in Lamlash Bay. This fish farm lies within the South Arran Marine Protected Area and I am opposed to any further expansion of open cage fish farming around Arran because of the clear negative environmental impact of 1000 tonnes of untreated salmon sewage being released into the water from this single farm.
The SSC say that they will be undertaking a ‘full Environmental Impact Assessment’; this is the minimum that we can expect NAC to be asking for in their screening and scoping opinion as there has never been an EIA at the site and the cumulative environmental effects are undocumented. I cannot understand why the company wants to expand the farm in an MPA and an area that the Scottish Environmental Protection Agency (SEPA) reports has only ‘Moderate’ water quality and they say will now not achieve ‘Good’ water quality until 2027.
The SSC are in pre-application conversations with NAC Planning and ahead of that application I am requesting that NAC use their discretionary powers to ensure that the views of the Arran community are taken into account when responding with the screening and scoping opinion, once the application is received. Scoping requests and reports are often offered for public consultation and NGOs like the RSPB are regularly consulted. In fact the Planning Officers’ Society guidelines state that ‘Where a formal Scoping Opinion is sought from a Local Planning Authority, it is mandatory for the authority to consult the statutory consultees. It is usually good practice to include relevant non-statutory consultees.’ I request that NAC planning implement ‘good practice’.
I understand that our local marine conservation charity, the Community of Arran Seabed Trust (COAST), had their request to be recognised as a consultee to the proposed screening/scoping refused. I request that you ask the planning department to reconsider this and ensure that they are consulted as they represent our views and are committed to an independent scientific approach to ensuring that the marine environment around Arran and the Clyde regenerates for the benefit of all.
Yours sincerely

Cc: Mr James Miller, Head of NAC Planning