Cumulative effect on landscape since 2012

Additionally, by law, the Council needs to consider the cumulative effect of this application with all other existing fish farms on Loch Etive.

This is not considered at all by Dawnfresh in its application. The graph below produced by FoLE shows the total surface area of Dawnfresh’s permitted fish-farm cages on Loch Etive in 2012, in 2016 and with the two more cages at Etive 6 (potentially granted by the DPEA, that application currently being on appeal this summer) and with this current application at Etive 3. The graph takes no account of the permanently moored feed barge at Etive 6 or the re-use at Etive 1 of moorings for the many industrial fish farm boats now moored there and elsewhere on the loch, both of which have also added to the landscape impact of Dawnfresh operations since 2012.

The Council has already noted that “there is an evident uneasiness amongst the community, ranging from misgivings as to where the appellants are headed with their overall operation on the loch, to outright opposition…”[6].

Increase in Dawnfresh cage surface area (sq metres) across Loch Etive 2012-2016

Patently, there has already been a massive cumulative landscape impact on Loch Etive from Dawnfresh expansion plans since 2012. No further salami-slicing of the various Dawnfresh projects should be permitted to avoid numerous small stepwise increases in cage size, such as this application at Etive 3, being considered together as part of a cumulative assessment.

As the Council has already accepted that “Loch Etive is…rather constrained not only by the number of consented aquaculture sites which raises cumulative impact considerations, but also by its particular characteristics and qualities which proved to be favourable for the establishment of the nascent fin fish farming in Scotland, but which are less suited to the scales of farm now finding favour within that sector“[7].

In exactly the same way as the Council found in the recent Etive 6 application for two more cages there, this application for more cages, with no stated intention to increase in biomass, simply fails to satisfy the requirements of Local Development Plan Policy LDP 3 and SG AQUA 1 and Policy LE AQUA 1 of the Loch Etive ICZM Plan.

As before, there are no economic arguments in support of the enlargement of Etive 3 which would warrant the setting aside of the adverse landscape visual and cumulative impacts that this application would bring.

[6] Para 6.11 of the Council’s Observations by the Planning Authority on the Appellant’s Grounds of Appeal, Planning Permission Appeal PPA-130-2056 Modification of Fish Farm From 10 No. 80m Circumference Cages to 12 No. 80m Circumference Cages including Increase in Extent of Mooring Area (No Increase in Biomass). Sailean Ruadh (Etive 6), Loch Etive, Argyll and Bute Council, 3rd June 2016.

[7] Para 2.3 of the Council’s Observations by the Planning Authority on the Appellant’s Grounds of Appeal, Planning Permission Appeal PPA-130-2056 Modification of Fish Farm From 10 No.80m Circumference Cages to 12 No. 80m Circumference Cages including Increase in Extent of Mooring Area (No Increase in Biomass). Sailean Ruadh (Etive 6), Loch Etive, Argyll and Bute Council, 3rd June 2016.

TOGETHER WE CAN PROTECT LOCH ETIVE, NOW, AND FOR FUTURE GENERATIONS