Ardentinny says NO to fish farm proposal


On 11 March, a special Community Council meeting took place to discuss the proposal by Dawnfresh Farming Ltd. to install a trout farm in Loch Long by the shores of Ardentinny.

The meeting was opened by Dawnfresh Farming Director, Alison Hutchins, who explained that they were in the very early stages of community consultation and that the purpose of the meeting was to gauge Impressions; impart information; and listen to the public’s comments and concerns. She went on to describe Dawnfresh as being the largest trout farming company in the UK, producing some 8000 tonnes for both the uk and export markets and looking to grow, with the Ardentinny site being one of 4 proposed new farms in and around the Firth of Clyde.

Dawnfresh Farming Director, Alison Hutchins.

Environmental Manager, Peter McDougall then went on to describe the proposed site location etc. inviting those present to view site maps he had brought along. He said they had undertaken computer modelling; seabed sampling; and wind and wave analysis and all suggest that it is a good site for farming trout. He stressed again that they are at the beginning of the planning application process, gathering opinion so that they can deliver “a site that will suit Ardentinny and not just something standard”. He said that there are 3 things the project requires to go ahead: 1. A CAR licence from SEPA; 2. Planning Permission; 3. A Marine Licence from Marine Scotland. All will be available for public comment and all will be advertised, as follows:

“The CAR licence application is advertised on the SEPA website, in the Edinburgh Gazette and in a local paper which in this case will be the Dunoon Observer.
The Planning permission will be advertised on the Loch Lomond and Trossachs National Park Planning Portal and in the Dunoon Observer.
The Marine Licence application will be advertised in the Dunoon Observer”

While they have submitted the CAR licence application, when we asked how we might find it on the SEPA website, Peter responded:

“The CAS scheme only relates to operational farms therefore only our existing farms have publicly available information on this sampling. Prior to developing a farm a baseline survey is undertaken and this is taken in a similar manner to the samples under CAS, i.e., grab samples of the seabed. The survey is submitted as part of the CAR licence application alongside the modelling report, hydrographic report, and video survey and report. These reports are with SEPA at the moment for consideration and once SEPA confirm all information is present and correct they will be published on the SEPA website and the application will be advertised.”

Dawnfresh Environmental Coordinator Peter MacDougall at Monday’s meeting.

After outlining the potential benefits of 6 jobs and additional work for service providers; support for community groups; help with moorings, beach cleans etc. Peter invited comments and questions from the floor. They were many, varied and insightful.

On predation…
Why choose a known spot for seals?
What would be done about them?
Would they be shot?
If acoustic deterrents were used they could stop seals coming to pup on the shore and negatively affect other sea mammals.

Dawnfresh responded by saying that while the RSPCA requires them to have a licence to shoot seals, they have not shot a seal since 2015 and have no intention of shooting seals. They consider that seals and fish farms can and do happily coincide, citing their Loch Etive farms as an example, and that a more effective form of control is the use of best quality nets.

On sea lice controls and consequences…
Some salmon farms use cleaner fish to deal with sea lice. Would that happen here?

Apparently, cleaner fish would not be used, as they carry a disease to which rainbow trout are susceptible. Instead they would be treated by a number of different measures. The Dawnfresh representatives could not recall the name of the ‘medicines’ used to treat the fish nor how often it is used. It is given in their feed or in shallow baths in the water and through the CAR licence process SEPA determines how much can be used. There are also other options such as hydrolysine and thermolysin. It was suggested from the floor that having the fish in tanks onshore could avoid the problems of predation and sea lice. This was considered to be financially non viable. In response to another question, fish mortalities would not go to landfill but would be collected by a contractor and the waste product sold on for use in such things as cosmetics etc.

On environmental concerns…
Several people expressed their concerns about effluent from the farm being washed up by the tide to Ardentinny bay and beach where children and animals play and swim and where visitors to the outdoor centre sail and canoe. Also that there was insufficient tide to take away the lice or treatments which could affect the seals, cormorants and other wildlife. It was pointed out that being in the Loch Lomond and Trossachs National Park, we had a duty to ensure that whatever we do is environmentally sound.

In addition, while tidal flow is very small, the area occasionally experiences huge tidal surges. The last one, approximately 20 years ago, washed the Gairletter caravans into the Clyde and flooded the Ferry house, resulting in a planning application for houses on the shore side of the Swedish houses being denied due to the risk of flooding. The damage that such a surge would cause to the fish farm pens and fish is unthinkable.

Asked what additional traffic impact there would be on the single track road, there was an assurance that this would only be the cars of the 6 staff with all other necessary transport coming by sea.

One resident remarked that Ardentinny was essentially a tourist village where people come to camp and enjoy the wildlife and general beauty of the place and the sight of an industrialised fish farm would have a negative visual impact. Another commented that growing fish beside a nuclear weapons store would not be a strong selling point.

On the bigger picture…
The potentially negative impact of having 3 other farms at a narrow end of the Clyde did not go unnoticed. It was suggested that any fish coming in from the Atlantic are going to pick up lice from these farms on their way to the river Leven and Loch Lomond beyond. Another posited that no fish would pass the sites and render the area barren.

When asked for a show of hands at the end of the meeting, 4 out of an audience of 62, indicated that they were in favour of the proposal.

When invited to comment on the meeting and in the light of that result, Peter McDougall said:

“We stand by our decision to engage with local people in Ardentinny early in what is a very complicated process in seeking permission for a trout farm near Ardentinny. As we often see when engagement is started early, there were a number of concerns expressed by people at the meeting because there are so many unknowns at this stage, but we were delighted to see people come out in such strong numbers which shows the level of interest. We will spend the coming months speaking with local people, giving them access to different experts and hopefully having them visit our existing site at Loch Etive to build confidence in the proposals, the process and Dawnfresh. We remain fully committed to the potential of a trout farm near Ardentinny and want to do that with the support of local people.”

19 March, 2018: Peter MacDougall has provided the following addendum:
The SEPA application has been submitted and includes modelling for the medicines Cypermethrin, Deltamethrin and Azamethiphos for use at the proposed farm. The confusion during the meeting was down to me attempting to explain that Deltamethrin and Cypermethrin are used routinely in animal medicine for terrestrial farming, that I thought may be more familiar to some of the audience, namely “Spot on” and “Crovect” sheep pour-on respectively. I couldn’t remember off the top of my head which way round they were hence the confusion.

Useful links:

EIA Screening documents for installation of fish farm (Loch Lomond and the Trossachs National Park – Planning)

Cumbrae fish farms online petition

Ardentinny Trout Farm Proposal – Community Council Meeting

An Ardentinny Community Council meeting has been announced to discuss the proposed Dawnfresh Ardentinny Trout Farm which is currently at the Environmental Impact Assessment screening stage (EIA) with Loch Lomond and the Trossachs National Park. An outline leaflet produced by Dawnfresh on the proposed trout farm has been posted on the village notice board.

According to the planning documents submitted to the National Park, the fish farm would be located on the outskirts of Ardentinny in Loch Long, south of the village and Ravenrock Lighthouse. The installation would consist of 10 – 38m diameter circular pens in a 5 x 2 configuration, placed in a 80m x 80m mooring matrix. The site would be serviced by a feed barge on the shore side holding at least 200T of feed. The location of the shore base in or around Ardentinny is yet to be decided.

The Ardentinny site is one of four proposed fish farms in the Clyde area. The other locations being Bute, Great Cumbrae and Little Cumbrae.

As part of the Ardentinny project, Dawnfresh proposes to service the site daily by boat from a shore base at Ardentinny and to employ a local workforce of six. The shore base may include office facilities, storage shed and access to the shore. Site boats will be located close to the shore base either at a pontoon or moorings.

Site of proposed fish farm (main Ardentinny road – from south)

The site will operate 7 days a week and fish stock will be delivered to the farm by wellboat. Stock will be grown on in the first year and will be harvested in the second year on an ongoing basis. Harvests will be undertaken by wellboat, initially using mobile harvesting equipment, at a yet to be determined nearby port.

A video survey has been undertaken beneath the proposed site and the results will be analysed and presented in the final planning application. An application has been submitted to Scottish Environment Protection Agency (SEPA) to confirm that the proposed biomass is within the carrying capacity of the area.

As part of the EIA screening application, Dawnfresh has addressed “Interaction with predators”. The report mentions that “Marine fish farms can experience considerable losses to predators if a predator identifies the farm as a viable food source”. Tensioned square mesh (30mm) top nets will be used to prevent predation by birds. The application also mentions that “Seals are initially attracted to a farm to graze on fallen stock and then move on to attack livestock. As a result, an attack has the potential to impact many thousands of fish and cause enormous stress on the rest of the fish population”.

In order to mitigate this, a daily collection of mortalities along with seal blinds (fine mesh) is envisaged. The application continues.. “If highly tensioned nets and daily removal of mortalities proves to be ineffective in deterring seals and in the event of full enclosure predator nets being inappropriate for use at this site Dawnfresh will consider the use of Acoustic Deterrent Devices (ADDs)”. “It is accepted that it may not be possible to totally eliminate predation by seals. Should mitigation measures be insufficient to protect fish stocks, Dawnfresh will consider the humane dispatch of a rogue seal”.

Landscape and Visual Impact Assessment
The application states that “Dawnfresh will undertake a full Landscape and Visual Impact Assessment (LVIA) in support on the proposed site. Photomontages will be prepared from key viewpoints which will be identified based on advice from our chosen landscape architect and further advised by SNH and the Planning Authority”.

Site of proposed fish farm (from north)

Community engagement
The company also states that it’s an active supporter of community engagement, in particular supporting beach cleans and providing staff and boats to assist in these operations as well as supporting community groups, organisations and events.

Construction of the proposed trout farm is estimated to take between two to three weeks.

Our local MSP and Ward Councillors were invited to comment on the proposal. Cabinet Secretary for Government Business and Constitutional Relations and MSP for Argyll and Bute, Mike Russell, considered that the key issues would be environmental pollution and escapes and what assurances are in place for these. He said “Given it is in the National Park, the guarantees would require to be cast iron in terms of technology for escapes and monitoring of environmental discharges.” Councillor Yvonne McNeilly said she would listen to the views expressed by all of her constituents, after community consultation.

The Community Council Meeting will take place in Ardentinny Village Hall on Monday 11 March at 7pm. All are welcome.

Useful links:

EIA Screening documents for installation of fish farm (Loch Lomond and the Trossachs National Park – Planning)
Dawnfresh corporate website
Friends of Loch Etive
Farmed trout escape in Loch Awe
Dawnfresh rush to repair net following breach
Sea Lice Breaching Farm List
Probe over chemicals at Scots fish farm as deaths increase
Jobs boost as new £8m fish farms plan is revealed

Slow down, save a life

Yet more roadkill on Ardentinny’s roads. This time what looks like a grouse killed on the bridge at Drynain. One does wonder as to the speed vehicles are travelling on this stretch of single-track road and why the drivers appear unable to avoid these creatures.



Community Councillor “horrified” at removal of nature trail

Entrance to the Discovery Trail
Entrance to the former Discovery Trail

A Community Council member has expressed her horror at the removal of the Forestry Commission Scotland (FCS) Discovery Trail behind the beach picnic area at Glenfinart Bay. Vehicles are no longer permitted to use the road to the nature trail and a locked metal gate has been erected at the foot of the road near the FCS house.

New gate at access road to nature trail
New gate at nature trail access road

The Councillor, Marian Norris, said she had made use of the trail many times and had organised camera club visits to the nature hide. “The nature trail is a fantastic facility for schoolchildren, especially as we are now attracting many people to the village with the Walled Garden and the beach. My feeling is that the Forestry Commission is no longer making recreation a priority in the area”.  She agreed that the trail was no longer suitable for those with disabilities and that she accepted that the small parking area be closed. However, she expressed a hope that the nature hide and information on the birds, flowers and trees could remain, as well as the paths and hide being kept open. She asked if a compromise could be reached to retain the facility.

David Robertson of FCS explained that, with the limited resources available to FCS and with the area not generating any income for FCS, it was pragmatic to focus on the most popular footpaths and to do these well. Indeed in the last year three staff members from the area had retired and had not been replaced. The facility also did not meet disabled criteria. In addition, David Robertson explained that there were also reports of anti-social behaviour and dumping of rubbish in the area, hence the installation of the gate near the FCS staff residence. He also pointed out that there are six other walks in the Ardentinny area which remain open. Information related to the trail is no longer sited at the location, nor will it be promoted by FCS, thus reducing Forestry Commission Scotland liability in the area.

Other Community Council members criticised FCS for not consulting the community on the closure and its failure to consult with residents on enhancing local facilities which had been discussed in previous years.

On a positive note, the suggestion was made that the community might participate in maintaining the nature trail with some possible assistance from Ardentinny Outdoor Centre. It was agreed at last week’s Community Council meeting that both the Community Council and Community Trust would explore this possibility with FCS.

Trail entrance
The former parking area at the trail entrance
Information signage on the trail
Entrance to the nature hide
The hide interior

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Discovery Trail