Screening and Scoping document

Dawn Fresh Foods has submitted a Scoping and Planning application to Argyle and Bute Council for a trout fish farm just south of Kilchattan Bay, along the shore directly paralleling the beautiful and popular West Island Way.

If you are keen you can read the scoping and planning application by following the link above. I have read it now several times and these are some of the things I am wondering about:


DFF lists the surface area of the farm as 11,485m2 = 1.2 hectares. They are only taking into account the surface area of the 10 38m diameter cages (16m deep). Yet there is a grid holding these cages in place, that I would suppose a vessel can’t cross over, so I wonder why this doesn’t get taken into account as surface area? Each cage is set within a 75m x 75m square so the 10 squares in a 2 x 5 configuration would cover 56,250m2 = approximately 6 hectares. In this area we could line up 10 of our ferries across by 5 ferries end to end, a total of 50 ferries fitting in that area.

Interestingly, the A&B Council form asks if the proposed site covers more than 1.2 hectares. Taking into account only the circular cage surface area, DFF has ticked No. I wrote to the Council on 19 March to ask what the significance of the 1.2 hectare was and received a response saying that my email had been passed to the FOI officer and I should receive a response by 17 April – I’ll let you know what they say if I get an answer.

By the way, if the moorings and anchors are taken into account, the area covered by the proposed farm as stated in the DFF application would be 880mx550m or 484,000m2 = 48.4 hectares.


Why is the maximum stocked biomass on the application listed as 2500Tonnes but in the box below that figure jumps 50% to 3750Tonnes listed per cycle? Underneath these two figures is a stocking density of 13.6kg/m3. Which of the tonnage figures is this stocking density based upon?

To learn more about why stocking density is important and the many other issues surrounding the welfare of farmed trout, follow this link to the RSCPA Welfare Standards for Farmed Rainbow Trout

DFF says that the site will be serviced from a shorebase on the Isle of Bute, a location for which is yet to be decided and will depend on availability should this application be successful Why is this not being explained more fully and why has the company not already looked into this matter? The farm proposal off the north of Inchmarnock back in 2006 assumed that they could use a slip at St Ninians or area on Inchmarnock but these were privately held and not available. The most recent proposal by Scottish Salmon Company for a site near Kilchattan Bay was in part abandoned because the proposed site was too close to the electric cable carrying our electric supply from the mainland. Where will the shorebase be? The farm is already being proposed against an isolated coastline of panoramic quality, very sensitive to development. Surely they can’t expect to put anything on this remote shoreline, so will they want to use the pier in Kilchattan Bay that belongs to Bute Estate? Or will they have a base in Rothesay? This should be explained in more depth to the people of Bute.

DFF says in the application that the farm will be in a new disease management area which may include two additional sites which DFF are currently seeking permission for should these proposals be successful DFF will operate all sites in the DMA which will allow synchronous fallowing and full sharing of information between sites.

I refer you to a document that can be found on the Friends of Loch Etive website, Friends of Loch Etive Grounds for Objection to Etive4 farm proposal. Here they address many of the concerns and problems that they have been dealing with in regards to the DFF fish farms sited in Loch Etive – and the problems are numerous. However, in regards to disease look at reason for objection 2 More sea-lice and the potential for fish disease threatening wild fish in Loch Etive. This will give you an idea of the problems that sea lice cause and this in turn is why Disease Management Areas are an important issue.

Now look at the Marine Scotland Science response to DFF fish farm proposal Bute, in particular pages 3, 4 and 6. The Bute fish farm proposal is not located in an existing DMA. And with the numerous other fish farms being proposed at the same time there are several issues that Marine Scotland Science raises. The thing that is worrying is that if the DFF proposal at Ardentinny is approved, creating its own DMA, before the Bute and Cumbrae farms then MSS will object to the Bute and Cumbrae proposals, however, if one or all of the Bute and Cumbrae proposals are approved, enlarging the existing DMA, then Ardentinny can be approved and incorporated into that very large area. This large DMA will then have multiple operators of multiple types of fish who will all need to coordinate their production cycles and share data. Cross company cooperation and transparency in sharing and reporting data is not what the Scottish aquaculture community is known for. This is shown in the Scottish Parliament’s Environment, Climate Change and Land Reform Committee: report on the environmental impacts of salmon farming. The link will take you to the report that was presented to the Rural Economy and Connectivity Committee in March 2018 but a review of the cover letter will give you an idea of what the report contained:

….report was focused on the environmental impacts of the industry in relation to the marine environment. Evidence to the Committee highlighted considerable additional environmental impacts, including in relation to freshwater environments. The key additional environmental impacts identified are set out towards the end of our report.

Overall the Committee concluded:

  • It is clear to the Committee that the same set of concerns regarding the environmental impact of salmon farming exist now as in 2002 but the scale and impact of these has expanded since 2002. There has been a lack of progress in tackling many of the key issues previously identified and unacceptable levels of mortality persist.
  • Over that period there appears to have been too little focus on the application of the precautionary principle in the development and expansion of the sector.
  • Scotland is at a critical point in considering how salmon farming develops in a sustainable way in relation to the environment. The planned expansion of the industry over the next 10-15 years will place huge pressures on the environment. Industry growth targets of 300,000 -400,000 tonnes by 2030 do not take into account the capacity of the environment to farm that quantity of salmon. If the current issues are not addressed this expansion will be unsustainable and may cause irrecoverable damage to the environment.
  • The Committee is deeply concerned that the development and growth of the sector is taking place without a full understanding of the environmental impacts. The Committee considers an independent assessment of the environmental sustainability of the predicted growth of the sector is necessary.
  • There are significant gaps in knowledge, data, monitoring and research around the adverse risk the sector poses to ecosystem functions, their resilience and the supply of ecosystem services. Further information is necessary in order to set realistic targets for the industry that fall within environmental limits. There should be a requirement for the industry to fund the independent and independently verified research and development needed.
  • The role, responsibilities and interaction of agencies requires review and agencies need to be appropriately funded and resourced to fully meet their environmental duties and obligations. Scotland’s public bodies have a duty to protect biodiversity and this must be to the fore when considering the expansion of the sector. We need to progress on the basis of the precautionary principle and agencies need to work together more effectively.
  • There need to be changes to current farming practice. The industry needs to demonstrate it can effectively manage and mitigate its impacts.
  • Scotland needs an ecosystems-based approach to planning the industry’s growth and development in both the marine and freshwater environment, identifying where salmon farming can take place and what the carrying capacity of that environment is. A cohesive framework is needed.
  • As a matter of urgency the Committee wishes to see independent research commissioned, including a full cost-benefit analysis of Recirculating Aquaculture Systems (RAS), and a comparative analysis with the sector as it currently operates in Scotland, alongside further development and implementation of alternative technical solutions, supported by the use of incentives.
  • Adaptive management which takes account of the precautionary principle, (using real-time, farm by farm data) could have the potential to reduce environmental impacts, but additional detail is needed on how it would be applied in practice
  • The Committee is supportive of aquaculture, but further development and expansion must be on the basis of a precautionary approach and must be based on resolving the environmental problems. The status quo is not an option.
  • The current consenting and regulatory framework, including the approach to sanctions and enforcement, is inadequate to address the environmental issues. The Committee is not convinced the sector is being regulated sufficiently,or regulated sufficiently effectively. This needs to be addressed urgently because further expansion must be on an environmentally sustainable basis.

The above report from the ECCLR Committee led to the National Trust Scotland demanding a moratorium on all new fish farms in May 2018: Wading into the Fish Farm Debate. In this article Senior Nature Conservation Advisor, Dr Richard Luxmoore, commented:

The Scottish industry last year lost more than a million fish to sea lice infestations. The impacts on wild fish are harder to measure, but they add to other factors leading to the collapse of wild salmon and sea trout stocks, for instance on the River Awe. Remarkably, there is no single government body with responsibility for the health of our wild fish. The chemical treatments used to tackle these infestations can also cause damage to wild species, including crab, lobster and langoustine, themselves economically important.’Luxmoore added: ‘These problems have been exacerbated by a failure to meet even current standards. The aquaculture sector was identified by the Scottish Environment Protection Agency as one of the least compliant sectors, with 20% of fish farms not meeting existing standards in 2015. A further problem is the waste food and untreated faeces discharged from fish farms.  A moderately large fish farm will dump the same amount of sewage as a town twice the size of Oban and, unlike human sewage, it is entirely untreated.’

All that we have looked at above regarding lice and other diseases that are spread from farmed salmon and trout to wild fish, the lack of government body oversight and failure of farm companies to comply, and the lack of research into the environment leading to growing an industry whose impacts are not entirely understood have lead to the following bodies writing negative responses to the proposed DFF fish farm proposal on Bute. In these letters they note their opposition to the other farms being proposed in the vicinity as well.

  • Argyll District Salmon Fishery Board
  • Ayrshire Rivers Trust a telling quote from this letter written on 1 March 2019 is: Dawnfresh Foods (DFF) have at no time engaged with ourselves or any of the 4 DFSB’s or angling interests within Ayrshire prior to application. This is disappointing and doesn’t foster good relations with local interests and stakeholders that may be affected by their proposals.
  • East Kilbride Angling Club
  • Fish Legal (letter from their solicitor)
  • Fisheries Management Scotland in their response they question the ability and resources of DFF to manage sea lice in rainbow trout in seawater, as opposed to the brackish conditions in Loch Etive. Sea lice cannot live in freshwater so the brackish water makes life a struggle for them; even so, for the past 5 years or more DFF has had sea lice problems that have required chemical treatments in the farms on Loch Etive. So, FMS raises a question as to what will happen when the sea lice do not have to struggle to survive and are in their natural habitat of sea water on the proposed farms off Bute and the Cumbraes?
  • Loch Lomond Angling Improvement Association


In response to the council’s question on what operational and management practices are to be put in place to ensure site containment and disease control DFF states that it has strict biosecurity measures for all its sites, with site containment and escape contingency plans in place. DFF may have written documents but here is information on escapes at the DFF farms in Loch Etive 2008 to 2018 (scroll 3/4 of the way down the page). This article reports on the February 2018 escape of approximately 5400 fish.

In response to a question regarding the methods that will be used to control predatory wildlife DFF says that their Predator Mitigation Plan proposes the use of Acoustic Deterrent Devices but this will be dependent on the Environmental Assessment and the presence of cetaceans in the area. Residents and visitors already know that there are many marine mammals in the waters around Bute so please spread the word to as many people as possible to record marine mammal sightings on the Marine Mammal Project online sighting form.

In response to the question of what level of local employment will be generated directly as a result of the proposal DFF says that there will be 6 jobs created on Bute and possibly ancillary service positions (jobs that sound like they will be done either by existing employees or shared across the 4 proposed sites – electricial, ROV operator, etc – and then crewing of a workboat and two net washing vessels. Though if all 4 sites are not approved will it be financially viable to build all these boats and pay for the crews? Let’s look at several threads here: the likelihood that all these jobs will materialise , the effect of the fish farm on existing jobs/potential job growth in other sectors and the financial state of DFF should be considered.

To discuss the likelihood of all the jobs materialising that are touted in the DFF Scoping and Planning document let’s look at the Clyde Marine Planning Partnership Clyde Marine Regional Assessment 2017 which is a comprehensive review of environmental, social and economic trends and issues at the Clyde Marine Region level. In the Summary that prefaces the content of Section 6.3 Aquaculture, the last paragraph says ‘The sector remains important for supporting rural and coastal communities both directly and through supply chain linkages, however, there has been an overall decline in employment‘. In Section 6.3.1 Contribution to The Economy, the report states that ‘The sector is a relatively small employer in absolute terms, however, provides year round employment for fragile rural communities in the region. Total direct employment(direct aquaculture jobs not supply chain such as office or processing plant jobs) is 160 jobs, although the employment base has declined by 30 jobs (16%) since 2010′. Under the heading Economic Output – Turnover and GVA (Gross Value Added) the report states that since 2009 there has been an increase in productivity fo the regions aquaculture industry. ‘This in part will be driven by the increase turnover but a decrease in employment i.e. businesses are growing turnover but with less employees. This is likely due to greater levels of automation across the sector‘.

Also, take a look at a 28 August 2017 article Tomorrows Fish Farms will be Unmanned

Please check back as I will continue working through the Scoping and Planning paper submitted by DFF for the Hawks Neb site on Bute …