MILLSTONE POINT SALMON FARM APPEAL BY SCOTTISH SALMON COMPANY TO THE SCOTTISH GOVERNMENT IS DISMISSED AND PLANNING APPLICATION REFUSED
APPEAL DECISION NOTICE
Planning appeal reference: PPA-310-2033 For full Report see Planning and Environmental Appeals Division www.dpea.scotland.gov
Decision by The Reporter 9th November: I dismiss the appeal and refuse planning permission.
Some of the pertinent unedited paragraphs covered in the 98 sections of the Reporter’s summary are included below:
Landscape and seascape character
26. There is no development within the maritime element of this seascape. There is both sailing and kayaking especially during the summer months but there are no anchorages off this coast. The coastline is rocky with large boulders and shingle beach generally backed by a very narrow coastal strip backed by outward facing slopes. I noted the “Fallen Rocks” as a feature of the south-eastern end of the bay these being huge rugged boulders which toppled into the sea. There is a prevailing sense of isolation and naturalness.
27. On that basis there is no dispute that the Sannox to Loch Ranza CCA would be highly sensitive to any forms of development including fish farms. The environmental report concludes the magnitude of change would be moderate within the coastal character area. Despite the limited geographical extent of the proposal proximity to the coast exerts an influence on the seascape. The effects would be reversible, and would result in a major/moderate, significant adverse effects. Significant seascape effects would focus on a small geographical area, within 2 km radius only. I agree there would be no cumulative impacts arising from the proposal.
28. The proposal would introduce man-made features in the water. Whilst the feed barge has been designed to resemble a fishing vessel it would be a static feature. There is no other anchorage or human activity on the shoreline of Arran. There would be activity associated with the operation of the pens and feed barge on the open water.
29. I accept the seascape in this location is large and expansive in scale extending towards Bute, Cumbrae, and the mainland. I consider the seascape to be sensitive and of a high quality and that is reflected in the appellant’s assessment. The more expansive nature of the seascape and coastline associated with this character area would result in a moderate change. Nevertheless due to the high sensitivity described above I consider there would be significant effects. There would be no cumulative impacts arising from the proposal.
30. In conclusion there would be significant albeit localised effects on landscape character and seascape.
31. The recreational importance of the Arran Coastal Path and of marine-based recreational activity is recognised in the high sensitivity ascribed to receptors and the resultant assessments of significance. However, I accept that the recreational experience of the proposal from a core path or the sea will be limited in duration and by direction of
travel and distance.
32. It is notable that there is no existing maritime element within the seascape. There is both sailing and kayaking but there are no anchorages off the coast. I walked the section of the footpath which extends along the shore and forms part of the Arran Coastal Route. It is a waymarked and clearly popular route enjoying seascape views and with points of interest arising from the landform and sea views and the huge rugged boulders known as the “Fallen Rocks”. Unlike other parts of the island there is a real sense of rugged and isolated coast with limited influence of man-made features. There is a corresponding lack of visible development looking out across the Sound of Bute.
33. The assessment of potential visual effects on views from the core path network, recreational viewpoints and water-based recreation activity, is summarised in Chapter 14 of the EIAR and a detailed assessment of the viewpoints is supplied in Appendix O. The location of the assessment viewpoints is also illustrated on Appeal Figure 1. The landscape is experienced from the Arran Coastal Way with panoramic views from the low lying core path and open water and out to sea. The Arran Coastal Way extends 105 kilometres on a circular route around the Isle of Arran.
34. It is clear from the appellant’s assessment and my site visit that the proposal would avoid multiple significant adverse visual effects across a large area. Instead significant visual effects are identified from different points within a very limited geographical area particularly in the context of land based visibility. For marine receptors water-based visibility rapidly declines to nearly imperceptible with the effect of distance out to sea.
35. The Isolated Coast as referenced above extends a length of 12.5 km between Lochranza and Sannox, of which 7.4 km is included within the Zone of Theoretical Visibility (ZTV), and predicted significant visual effects would be restricted to recreational users of a short section within a 2 km radius. Wider visibility along the coastline and shoreline would reduce with distance especially out to sea and depending on the alignment of the coastline, and potential screening elements for example the Fallen Rocks or local tree cover.
41. In summary there are no effects on the local road (A841) as the development cannot be seen. Given the popularity of the area with walkers and the full views of the pens and the feed barge from a section of the Arran Coastal Way the effects are predicted to be adverse and of moderate to major significance depending on proximity. Boat users travelling close to the foreshore would experience the greatest change in view and of an adverse nature due to the introduction of man-made maritime features here.
42. I appreciate the localised extent of visual effects. I also appreciate that fish farms are often characteristic of a coastal location. However the coastal path enables access to this isolated coast and I consider that isolation and natural character are key and valued characteristics of the area.
43. For visitors walking the Arran coastal way, in this locality, the experience of this currently natural area generally undisturbed by man-made features would be significantly changed with the introduction of the pens, the barge and associated activity in proximity to the shore. Given the nature of the shallow bay and the absence of man-made features I consider the infrastructure would be an incongruous and distracting element in views along the bay, out to sea and from boats travelling along and in proximity to this section of Arran’s coastline. I consider that given the location of the coastal path and the access it affords a high value and sensitivity is appropriately placed on the relatively untouched nature of the landscape and the openness of the existing views across the sea.
44. I consider the introduction of the fish farm so close to the coastal path would detract from the amenity and character of the area as experienced by walkers and those passing by close to the coast on boats, canoes and other marine craft. The value placed on this area and the experience of isolation and openness are reflected in the responses received on the application and subsequently at appeal. There would be significant albeit localised visual effects.
Landscape and Visual Mitigation
45. I understand mitigation is embedded within the design limiting the proposal to 12 pens and designing the feed barge to resemble a fishing boat and the use of a grey colour to reduce prominence in any view. In addition shore based infrastructure is avoided given the existing shore base at Lamlash. The height of the proposed pens and other infrastructure is limited to maintain a low profile appearance. However the proposal would remain a significant incursion of infrastructure into an undeveloped and isolated area of coast. I do not consider the proposed mitigation sufficient to address my concerns regarding the significance, albeit local significance, of the landscape and visual impact of the proposal.
National Scenic Area and Special Landscape Area
46. The site is within the National Scenic Area boundary as shown in Appeal Figure 2.
47. The special qualities of the NSA considered relevant to this application are: i) a mountain presence that dominates the Firth of Clyde ii) that it has a contrast between the wild highland interior and the populated coastal strip; iii) that is has a distinctive coastline with a rich variety of forms; iv) it comprises the historical landscape in miniature; v) it is exceptional for outdoor recreation; and vi) the experience that highland and island wildlife is close at hand.
48. In my assessment, as supported by the EIAR, the proposed location, scale and nature of the proposal is not such as to represent a significant detraction from the profile of the islands peaks when viewed from the Firth, North Ayrshire, Kintyre, Bute and from many places inland or out from Arran. In the main the existing perception of the distinctive coastal landform rising from the Firth when viewing the Isle of Arran from the water, or from the coastline of Bute or North Ayrshire would be retained.
49. Nevertheless I consider that the area subject of this proposal contributes to the rich variety of coastline being an area of distinctive natural and undeveloped character. In turn that naturalness and the proximity of the coastal path to the sea with limited man made disturbance contributes to the experience that wildlife including sea life is close at hand. The path as a popular coastal route provides an important recreational resource.
50. NatureScot considers that the visual impact would result in significant adverse effects on the special qualities such that the objectives of the designation and its overall integrity would be compromised. On the other hand the assessment included in the Environmental Reports concludes that the overall integrity of the designation would be protected given the magnitude of change would be negligible within the designation as a whole.
Congratulations to all those who worked tirelessly over many months to ensure that North Ayrshire Council appreciated our wlld coast and landscape value, those who wrote letters, organised walks to our north coast area, organised media inputs, organised petitions, did analyses of the science, and of the economic case, wrote again and again, to MSPs, newspapers, and anyone interested in sustainability of our Scottish landscapes and marine environments; who took photos and videos, utilised social media, who used their boats, their kayaks, and some creative posters to spread the message that this was not a place for the salmon farm. It can be done! A huge community of effort, from visitors, other islands, (especially Bute) and Clyde Communities. Of course, there were other opinions and these have been given expression both in the island press and in formal consultation. More secure economic opportunities diversifying away from the central theme of tourism are needed for the future. However, the Reporter has arrived at a reasoned decision that this proposal was not the answer.
Words of thanks from Sally Campbell, November 2021