What is the real purpose of the current application?

In this current application, Dawnfresh states clearly that “the purpose of this development is to standardise our equipment within our operations in Loch Etive, this will improve our efficiencies within the operations” and, they claim, not part of a process to increase permitted biomass of farmed fish to be held at Etive 3.

On page 2 of the Supporting Information, Dawnfresh also recognises that “the stocking density at Etive 3 site will be reduced to 5.1kg/m3, which is exceptionally low. We recognise that this stocking density is extremely low compared to industry standards, however it is essential that we standardise the equipment that is used on all the sites in Loch Etive”.

If, as the application states on a number of occasions, there is really no intention whatsoever to increase the biomass of farmed fish held at Etive 3, then in order to ‘standardise’ the use of equipment on Etive as a whole by using 80m cages, it is simply not necessary to apply for a total of ten cages.

In fact, the existing permitted biomass at Etive 3 can be held at the ‘standardised’ stocking density of 11.81kg/m3, at which level Dawnfresh qualifies for RSPCA-assured status, can be held within only five 80m cages.

Unless the intention is to increase permitted biomass of farmed fish at Etive 3 at a later date, Dawnfresh has not reasonably demonstrated the need for 10 x 80m cages to maintain the current biomass of farmed fish at Etive 3. As such, the Council should not grant permission for 10 x 80m cages, interfering with public rights over Loch Etive without any apparent purpose.

In fact, it is impossible reasonably to consider this application as anything other than a first step in Dawnfresh attempting to ‘salami-slice’ its way to a larger farm at the Etive 3 site. Indeed, the intention to seek a much bigger farm at Etive 3 has been confirmed by Dawnfresh itself. As indicated by Dawnfresh at the Planning Hearing relating to application 15/02607/MFF, for more cages at Etive 6, held at Oban in February 2016[2], Dawnfresh actually intends to develop a whole new farm at Etive 3, increasing the permitted biomass on the loch by 1,050 tonnes (which would bring Etive 3 up to about 1500 tonnes from its current biomass of 466 tonnes) and allowing a growth of 23% in the production capacity of the loch as a whole. As its second application above, only recently withdrawn, indicates, a permanently moored feed barge also remains part of Dawnfresh future plans for Etive 3.

This is all part of the Dawnfresh plan to push the biomass of its farmed fish held in Loch Etive even higher still. That biomass has already increased 500% since 2010 as the graph below, drawn up using SEPA data shows. The intention is to go further, beyond a standing biomass of 3000 tonnes, which FoLE believes Loch Etive simply cannot accommodate.

Total biomass (tonnes) on Dawnfresh farms in Loch Etive 2010-2016 from SEPA data

As the Council has already recognised – and stated in the context of the earlier application for more cages at Etive 6 – “consideration of a follow up application in these circumstances therefore has to be approached cautiously, in order to ensure that policy considerations are not being deliberately circumvented by the division of a project into multiple applications”[3].

Albeit, that we are in the first stage of Dawnfresh’s stated Etive 3 plan, the principle remains the same, that policy considerations must not be deliberately circumvented by the division of a project into multiple applications as Dawnfresh is doing here.

[2] Slide 14 of the Applicant’s PowerPoint presentation delivered in February 2016 (reproduced as Annex 1 of this objection).

[3] Para 6.6 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.