HELP US STOP MOWI’S SALMON FARM EXPANSION.

We need as many people as possible to help us oppose their planning application and persuade the local council to reject their plans. If you wish to find out more on why we oppose the expansion click here.

Firstly
You can read Mowi’s application and EIA report online here.

Before commenting on their planning application please read our step by step guide to help make your voice count and send in your comments by post or online by the deadline of 9th January 2022

Planning application Ref 21/05582/FUL

Step 1

Set up an account
If you wish to comment on a planning application online, you must first register with Highland Council Planning

Step 2

Decide what you want to say

Make some notes about your grounds for objection under as many of the numbered headings below as you can. What you think, feel and fear are important. It’s fine if you just want to comment on one thing.

You can use our guide below to help, it contains a quick guide, template letter and resources if you wish to go into more detail.

Step 3

Save your comments then submit them

There is a 10 minute timeout on pages. If this time passes and you are still typing, any information you then submit will be lost. If you have a lot of information to be typed, we advise using something like Microsoft Word to compose your statement, and then copying this into the text box on the website. Comments submitted are also limited to 5000 characters, and you cannot add file attachments.

You can object, support or make a general comment on an application within 21 days of the date that the application was registered with the Council, when you received a neighbour notification or where it was advertised by the planning authority, whichever is the later.

If your comment exceeds the 5000 character limit or you need to add an attachment, please email directly to eplanning@highland.gov.uk or post it in writing to eProcessing Centre, Headquarters, Glenurquhart Road, IV3 5NX.

Closing date for comments is 9th January 2022

Comment Guide and Additional Information

The Planning Authority will only take into account ‘material considerations’, which relate to the use of the land and have a close link to the proposed development.

For the expansion of the salmon farm in Loch Hourn and its associated onshore impacts, these are the most likely ‘material considerations’.

For wildlife

  1. The effect on Priority Marine Features List Habitats and Species
  2. The effects on wild salmon and sea trout and wild fish; ; See response from WRASFB 2018 and the 2019 Newsletter of the Skye and Wester Ross Fisheries Trust 2019

For landscape

  1. The visual effect and impact on the designated National Scenic Area, the Wild Land Area and the Special Landscape of a large industrial site.

For the local community

  1. Any disruptive effects on the local economy – e.g. incompatibility with or displacement of other economic activity e.g. shell fishing, fishing, mountaineering, tourism on land and sea.
  2. Human health and well-being impacts on local residents from – e.g. noise (use, not construction) lighting, highway safety, traffic, etc
  3. The effect on cultural heritage
  4. The effects/combined effects of 1-6 on your health and well-being
    IAIA Scoping
    IAIA Human health: Ensuring a high level of protection;
    SEPA position statement on land use planning, health and wellbeing

We have broken it down a short template below which you can use to produce a quick quide/ objection, alternatively we have a longer full detailed guide to help you produce a more detailed objection. This site also contain additional information of the effects of Fish farms on our local environment.

Read ‘Filling in the objection form’ Section on commenting on an application – 2 minutes!

Write your objection using the template below as a guide. Delete sections that you don’t want to comment on and the sections in italics, if you would prefer to use your own words –  or refer to examples from ‘Planning Democracy’ for help(LINK)Try to explain/give reasons why the extension will increase the impact on receptors (eg people, wild salmons, landscape, tourists) and what the consequences will be (effects).

Filling in the objection form:

  • You can object, support (or object or support an application on conditional terms), but make your position clear: e.g I object to this application on the following grounds….etc.
  • Comments are limited to 5000 characters. Keep your comments short and to the point and only raise ‘material considerations’
  • If you wish to write more than 5000 characters or add attachments, please email directly to eplanning@highland.gov.uk or post it in writing to; eProcessing Centre, Headquarters, Glenurquhart Road, IV3 5NX.
  • Use bullet points to make it easier to read.
  • If you are submitting online, type out your comments in Word or Apple notes etc, save and then when ready, copy and paste into the text box on the planning website. (Keep a record!)
  • To avoid your submission being redacted or rejected in its entirety:
    • do not refer to the personal character or motives of the applicant(s)
    • do not make any abusive, salacious, defamatory or malicious comments or use libellous language
    • do not mention hearsay or rumour
    • Send in your comments before the deadline of…..or they are very likely to be ignored unless you contact the planning officer and you are given an extension.

View the template

Read Sections A, B, C, D below

Copy and fill in the template below (max 5000 words)

Suggestion:  3 bullet points for each heading

 

Section A: Filling in the objection form

 

  • You can object, support (or object or support an application on conditional terms), but make your position clear: e.g I object to this application on the following grounds….etc.
  • Comments are limited to 5000 characters. Keep your comments short and to the point and only raise ‘material considerations’
  • If you wish to write more than 5000 characters or add attachments, please email directly to eplanning@highland.gov.uk or post it in writing to; eProcessing Centre, Headquarters, Glenurquhart Road, IV3 5NX.
  • Use bullet points to make it easier to read.
  • If you are submitting online, type out your comments in Word or Apple notes etc, save and then when ready, copy and paste into the text box on the planning website. (Keep a record!)
  • To avoid your submission being redacted or rejected in its entirety:
    • do not refer to the personal character or motives of the applicant(s)
    • do not make any abusive, salacious, defamatory or malicious comments or use libellous language
    • do not mention hearsay or rumour
    • Send in your comments before the deadline of…..or they are very likely to be ignored unless you contact the planning officer and you are given an extension.

 

Section B: Policies and Plans

 

If you do have time, it is good practice to refer to policies and plans if you don’t think that the development is in accordance with the local plan or higher-level policies and statutory documents.

 

  1. The law requires that decisions will be assessed in terms of their accordance with the Highland Wide Development Plan (2012) unless material considerations indicate otherwise. The West Highlands and Islands Local Development Plan (2019) (WestPlan) may also be taken into consideration.
  2. Higher level policy and plans will also be material e.g. Scottish Planning Policy and the National Marine Plan, but they are likely to be encapsulated within the relevant policies of the development plan.
  3. The emerging National Planning Framework 4 should be a material consideration, as the draft is now published. Unlike NPF3, it will be part of the statutory ‘development plan’ to which all planning authorities and the Scottish ministers must have regard in their planning decision-making. This document states: It is likely that NPF4 will be engaged much more frequently in local plans.  The direction of travel for national planning policy signals a key shift towards a net zero agenda and sets out Scottish Government thinking over four key themes – net zero emissions, resilient communities, wellbeing economy, and better, greener places. https://www.lawscot.org.uk/members/journal/issues/vol-66-issue-10/planning-covid-and-npfd-update/

 

Section C: Relevant policies in the HwLDP

 

Policy 50 Aquaculture of the HwLDP “supports the sustainable development of finfish and shellfish farming subject to there being no significant adverse effect, directly, indirectly or cumulatively” on “the natural, built and cultural heritage” and existing activities. The policy specifies various aspects of the above, that should be assessed including: landscape character, scenic and visual amenity; wild fish populations; biological carrying capacity; and cumulative benthic and water column impacts.

Assessment of existing activity should include consideration of commercial inshore fishing grounds; existing and consented aquaculture sites; and established harbours and natural anchorages and navigation (including recreational).

Wildlife

Policy 57 When dealing with a planning application for a development (which is likely to have a significant effect on a European site either alone or in combination with other plans and projects) where we are unable to ascertain that a proposal will not adversely affect the integrity of a European site, the proposal will not be in accordance with the development plan.

There will be likely significant effects on the Inner Hebrides and the Minches Special Area of Conservation (SAC) (porpoise is the qualifying feature) if Acoustic Deterrent Devices (ADDs) are used. (A licence is required from Marine Scotland if porpoises or other cetaceans are disturbed).’

Policy 58 Protected Species

Policy 59 Other important species

Policy 60 Other important habitats

Landscape, Seascape and Visual Effects

Policy 50 – as above

Policy 57 Natural, Built and Cultural Heritage sets out the safeguarding criteria for designated features that will be applied in considering development. For features of local/regional importance, the planning authority “will allow developments if it can be satisfactorily demonstrated that they will not have an unacceptable impact on the natural environment, amenity and heritage resource.”

Policy 28 Sustainable Design requires impacts on landscape, scenery and individual and community residential amenity to be considered, along with an assessment as to whether proposals demonstrate sensitive siting.

Policy 36 requires an assessment of whether the siting and design of a development are acceptable and compatible with landscape character and capacity.

Policy 61 Landscape New developments should be designed to reflect the landscape characteristics and special qualities identified in the Landscape Character Assessment of the area in which they are proposed.

 

Pollution

Policy 63 Water Environment

The Council will support proposals for development that do not compromise the objectives of the Water Framework Directive (2000/60/EC), aimed at the protection and improvement of Scotland’s water environment. In assessing proposals, the Council will take into account the River Basin Management Plan for the Scotland River Basin District and associated Area Management Plans and supporting information on opportunities for improvements and constraints.

Policy 72 Noise, Air, Water, Light

 

Section D: Environmental Report

 

Read the Environmental Report (ER) (from the applicant’s Environmental Impact Assessment)

From 2017, additional environmental factors were introduced for consideration: biodiversity, climate, population and human health and project vulnerability

NB If a scoping opinion has been produced (2018), the ER should confine itself to what has been scoped in, unless the baselines have changed. Although the planning authority must take account of the ER, it does not base its decision on the ER alone.

If you do not agree with the ER, make a comment in your submission, explaining why and if appropriate backing up with evidence. Reference the paragraph in the ER.

The Environmental Report (ER) would normally contain a Seascape, Landscape, and Visual Impact Assessment (SLVIA) of the proposed extension. This will be based on scoping advice from HC, Nature Scot and possibly Historic Environment Scotland (HES) However, see Appendix 19 LOCH HOURN SALMON FARM LANDSCAPE AND VISUAL STATEMENT under the Documents tab on the online application, as no LVIA has been required. You may wish to comment on this.

The SLVIA assesses the potential impacts of the proposals upon Seascape and Landscape Character Areas and key viewpoints. Specific receptors are likely to include: wildness, tranquillity; dark skies/ sky glow; cultural heritage; settlement and dwellings; roads; and tourism.

See Nature Scot

https://www.nature.scot/doc/siting-and-design-aquaculture-landscape-visual-and-landscape-considerations

See Nature Scot – Guidance for applicants on what is required for the Environmental Report in terms of visual impact: https://www.nature.scot/sites/default/files/2018-02/Visualisations%20for%20Aquaculture%20-%20Guidance%20%20Note.pdf

See Nature Scot Landscape Policy on Wild Land (‘Wild Land’ is non statutory, but considered of National Importance):

https://www.nature.scot/professional-advice/landscape/landscape-policy-and-guidance/landscape-policy-wild-land

The (soon to be replaced) NPF 3 regards Wild Land as meriting strong protection:

The Scottish Government’s National Planning Framework 3 June 2014 states at para 4.4

‘Scotland’s landscapes are spectacular, contributing to our quality of life, our national identity and the visitor economy. Landscape quality is found across Scotland and all landscapes support place-making. National Scenic Areas and National Parks attract many visitors and reinforce our international image. We also want to continue our strong protection for our wildest landscapes –wild land is a nationally important asset.’

HwLDP on National Scenic Areas (NSA)

Generally these were established by Order under planning legislation by the Secretary

of State in 1981 on the basis of “Scotland’s Scenic Heritage” (Countryside Commission

for Scotland, 1978). They are defined as areas of “national scenic significance …of unsurpassed attractiveness which must be conserved as part or our national heritage.” However, the Planning etc

(Scotland) Act 2006 renews the powers of Scottish Ministers to designate NSAs where an area is of outstanding scenic value in a national context. Thereafter special attention is to be paid to the desirability of safeguarding or enhancing an NSA’s character or appearance. These areas are

protected by national policy in that the integrity of the area or the qualities for which it has been designated should not be adversely affected. SNH have produced a report, National Scenic Areas Special Qualities, which details landscape qualities that make National Scenic Area special.

 

Further References

This is a useful guide to responding to planning applications, which gives examples of how to frame an objection, by reference to policies, the local development plan and material considerations.

https://www.planningdemocracy.org.uk/wp-content/uploads/2020/03/PD_HOW-TO-RESPOND_MAR20.pdf

Main website: https://www.planningdemocracy.org.uk/

Material considerations

https://www.improvementservice.org.uk/__data/assets/pdf_file/0016/24433/Planning-Sytem-in-Scotland-EM-Introduction.pdf at page 27, but note that there is no set definition of ‘material consideration’ and lists are non-exhaustive. This guide was written for councils, but useful

View the template

Example template for submitting a comment to a planning application

 

Planning reference number: 21/05582/FUL

Application description

Mowi application for an extension of the salmon farm in Loch Hourn

I object to this application on the following grounds:

  1. There will be an increased negative impact on key receptors listed below, resulting in significant adverse effects on these species and habitats of conservation importance.
    Priority Marine Species…
    Wild salmon and trout…
    Benthic habitats…
    Water column
  2. The proposed extension will further detract from the sense of wildness and tranquillity of the National Scenic Area and Wild Land Area. It is not in accordance with policies 28, 36 and 61 (LINK)) for the following reasons:(eg describe effects)
    Seascape …
    Landscape…
    Scenic and Visual Amenity
  3. The proposed extension will increase the negative impact on existing economic activities in Arnisdale, Corran and Knoydart. It also does not align with FoLH restoration projects to restore habitats and species (LINK?)and is therefore not in accordance with NPF4 plans for resilient communities (LINK)
    Fishing grounds and other wild fish
    Existing and consented aquaculture sites eg shell fishing
    Restoration projects – native oyster reefs, seagrass, maerl
    Harbours, anchorages and navigation
    Future local food security
    Tourism on land and sea
  4. The proposed extension will increase the negative impact on the health and well-being of the community: (Policy 72)
    Noise
    Odour
    Light pollution
    Further change in character of a remote, rural area/
    Land-use/Sea use becoming more industrial
    Traffic and safety problems

This proposed extension is not in overall accordance with the relevant policies in the Highland wide Local Development Plan (2012) (HwLDP) for the reasons stated above.

Name….

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