Update from AFF, brought to the Ardentinny CC meeting held 1st July 2019
AFF the Clyde Update to the Community Council
AFF the Clyde has had a busy few months since it was formed in order to fight the Industrial Fish Farm development at Ardentinny which has been proposed by Dawnfresh.
- Research has been carried out regarding residents’ views of the proposed development, and a comprehensive report has been produced. 90% of residents were against the proposal; concerns expressed included chemical pollution, impact on wildlife and impact upon the village environment.
- AFF the Clyde has set up various digital media. This includes:
Twitter/Instagram : @AFFtheClyde.org
Facebook Discussion Group: https://www.facebook.com/groups/AFFtheClyde
Facebook Page: https://www.fb.me/AFFtheClyde/
- An on-line petition has been set up with 38 degrees and has over 1000 signatures. We would appreciate as many people signing as possible, so if you haven’t signed yet and are against the proposed Fish Farm, please visit the site and sign the petition.
Petition: : https://tiny.cc/afftheclyde
We also have paper copies of petitions around the locality.
- The group responded to the SEPA CAR L application made by Dawnfresh and prepared a comprehensive objection to the proposals.
- Application for funding has been made to the Ardentinny Renewables Trust to cover basic expenses, and we are waiting to hear the outcome.
- Contact has been made with the Dunoon Observer who ran an article about AFF the Clyde. Several letters against the fish farm have also been published,
- Contact has been made with Kilmun and Arrochar Community Councils who have expressed support for what AFF the Clyde is trying to achieve. We are continuing to liaise with Ardentinny Community Council regarding our plans.
- Contact has been made with the MSPs elected to Cowal and with local councillors. We have had varying degrees of success in eliciting support against the Fish Farm.
- We have been building a community presence and have had a stall at the walled garden party. We have also had a window display at Bookpoint in Dunoon.
- Links have been made with the Bute group Buteiful Coast who are affected by Dawnfresh’s proposal to develop an Industrial Fish Farm at Hawk’s Neb and AFF attended an information meeting hosted by Buteiful Coast regarding the proposals. We have also been receiving advice and support from people who have expert knowledge regarding the impact of fish farming.
- AFF have expressed interest in attending the visit to the Loch Ewe Fish Farm that Dawnfresh have promised to arrange. We are yet waiting to hear when this visit may take place.
- We were given a donation which enabled us to purchase 400 leaflets which have been distributed in various locations, 2 roll-up banners and 2 PVC banners which were put up at the site of the proposed fish farm and which. Regrettably the PVC banners have been stolen, presumably to suppress debate.
AFF the Clyde is hoping to attract more active members. If anyone is interested, please e-mail Jann Garratt, Stuart Maslin or Ann Wood at : : https://tiny.cc/afftheclyde
Letter of objection from Ardentinny Community Council to Sepa regarding proposed fish farm.
Ardentinny Community Council
Convenor Neil Robinson
Dingwall IV15 9XB
4 June 2019
CAR Application - Dawnfresh Farming Limited CAR/L/1178003
Ardentinny Community Council wishes to express its opposition to this proposal.
We do so in the belief that the Dawnfresh proposal is ill-judged as to its location and design, failing to reflect current scientific evidence concerning sustainable aquaculture as recognised by SEPA.
We note, in particular, that SEPA has recently completed a period of research and consultation that has lead it to conclude that the existing regulatory approach is outdated and does not “adequately protect marine life” and that accordingly SEPA will be introducing
“a revised regulatory regime that will strengthen the protection of the marine environment for the people of Scotland” in June 2019.
It seems particularly unfortunate that the Dawnfresh proposal has been submitted shortly before these new regulations come into force.
We welcome the fact that the SEPA statement continues:
“In practice, we anticipate this [new regulatory framework] will lead to fewer fish farms in shallower, slow-flowing waters and more fish farms in deeper and faster-flowing waters. We also anticipate it will encourage the adoption of new technologies such as partial and full containment to capture organic waste and any remaining medical residues. SEPA has seen some industry operators successfully developing new approaches such as non-chemical ways of managing fish health. Our new regime will support these encouraging developments.”
However, the Dawnfresh proposal meets none of these criteria, being in shallower, slower-flowing waters, far from the open sea and located in a fragile and already damaged environment. Furthermore it does not address the issues raised in the new Regulatory Framework : it does not mention any of the new approaches that SEPA has recommended, such as non-medicinal farming using wrasse, full or partial containment or enhanced fallowing.
It relies, therefore, purely on older, outdated methods.
It is to be welcomed that the Dawnfresh Non-Technical Summary explicitly states that in-food medicine is not being proposed, given the recent evidence concerning Emamectin benzoate.
However, this approach means that Sea Lice control will rely entirely on the use of bath treatments, using Cypermethrin, Deltamethrin and Azamethiphos, all of which pose a serious risk to the marine environment if used in excessive dose.
For instance the European Agency for the Evaluation of Medicinal Products states that Azamethiphos has a “low therapeutic margin of safety” and SEPA has stated that “ it is possible that all uses will eventually be phased out through European legislation”.
With regard to Deltamethrin, we are concerned that there is evidence that the effects may be felt well away from Fish Farm itself, as Ernst et al (2014) found mortality and paralysis effects on amphipods up to 350m from cages. This is the approximate distance from the Fish Farm to the beach at Ardenfield in Ardentinny Beach, a popular recreational area.
We note that Cypermethrin is a priority substance for action under the Water Framework Directive.
Recent studies have confirmed that Sea Lice are increasingly developing resistance to such treatments. This problem is exacerbated by the limited number of treament chemicals available and so is likely to become more pronounced given that in-feed treatment is not proposed by Dawnfresh.
If resistance does develop (or develops further, if Sea Lice in Loch Long have already been exposed to these treatments in other facilities) then it is possible that maximum dosage will be insufficient to contain Sea Lice infestation. This will result not only in high mortality to dawnfresh stock, but also to wild Salmonids in the Loch.
Further, we are concerned about the possibility of excessive doses being given, in that SEPA reports that a significant proportion of the 19% of non-compliance reported in 2017 involved “quantities of medicines used exceeding that permitted”.
The Community Council is also concerned that this proposal has not considered the treatment for other diseases that Rainbow Trout may be prone to, given that these include those “caused by bacteria (bacterial gill disease, furunculosis, bacterial kidney disease, fin rot), parasites (Gyrodactylus, Chilodonella, Trichodina, Epistylis, Trichophrya, Ichthyopthirius, Ichtyobodo, proliferative kidney disease, amoebic gill infestation, Coleps), fungi (Saprolegnia), and viruses (infectious pancreatic necrosis, viral hemorrhagic septicemia, and infectious hematopoietic necrosis)”(Noble and Summerfelt 1996). No mention is made in this proposal on how such infections would be dealt with and what treatments might be used. In particular, the proposal fails to mention what antiobiotics are intended to be used. However, the Farm Antibiotics report for 2017 stated that usage data for 70% of the trout sector showed mean antibiotic usage levels of 19mg/kg for trout.
The Community Council is also concerned about the apparently casual approach of this proposal (for instance the error in Form C Section 2, 2.1) and the absence of any thorough study into the ecology and local conditions pertaining to this site.
The Community Council’s objection to the proposal is reflected in the community’s overwhelming opposition. A survey of residents, carried out by the Community Council and which had a 90% response rate, found that 73% opposed the Dawnfresh application.
The Community Council believes that this proposal falls far short of SEPA criteria. We request, therefore, that SEPA rejects this application or, at the very least, delays approval until it can be considered fully under the new, improved regulations that have been designed to enhance environmental protection, reflecting improved technology and scientific understanding.
Rob Bray Ph.D.
on behalf of Ardentinny Community Council
 SEPA https://www.sepa.org.uk/regulations/water/aquaculture/bbc-panorama-response/ accessed 26/5/2019
 SEPA 2018 Fish Aquaculture Sector Plan Annexe 1
 SEPA 2018 Fish Aquaculture Sector Plan p 19
 WAT-PS-17-03: INTERIM POSITION STATEMENT FOR PROTECTING THE WATER ENVIRONMENT UNTIL SUCH TIME AS A DIRECTION IS ISSUED ON AN EQS IN RELATION TO EMAMECTIN BENZOATE IN FINFISH FARM REGULATION file:///media/fuse/drivefs-d54039453ba43b6b45504ef59c4bd652/root/Rob%20Misc/Community%20Council/Fish%20farm%202019/SEPA%20docs/sepa_position_statement_implementation_of_car.pdf
 European Agency for the Evaluation of Medicinal Products 1999 EMEA/MRL/527/98-Final
 http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=169 Accessed 30 May 2019
 Ernst, W., Doe, K., Cook, A., Burridge, L., Lalonde, B., Jackman, P., ... & Page, F. (2014). Dispersion and toxicity to non-target crustaceans of azamethiphos and deltamethrin after sea lice treatments on farmed salmon, Salmo salar. Aquaculture, 424, 104-112.
 SEPA Scottish Pollutant Release Inventory Cypermethrin http://apps.sepa.org.uk/spripa/Pages/SubstanceInformation.aspx?pid=135 Accessed 30 May 2019
 For instance: Kaur, K., Jansen, P. A., Aspehaug, V. T., & Horsberg, T. E. (2016). Phe362Tyr in AChE: A major factor responsible for azamethiphos resistance in Lepeophtheirus salmonis in Norway. PloS one, 11(2), e0149264.
 SEPA 2018 Fish Aquaculture Sector Plan p 19
 Noble, A. C., & Summerfelt, S. T. (1996). Diseases encountered in rainbow trout cultured in recirculating systems. Annual Review of Fish Diseases, 6, 65-92.
 Farm Antibiotics https://www.farmantibiotics.org/media-news-updates/progress-by-sector/fish-production/ Accessed. 30 May 2019
Request from Dawn Fresh
The Dawn Fresh Fish Farm group have offered to put on a Visit to Dawnfresh’s trout farm at Loch Etive so they can see a trout farm in operation and what they are proposing for Ardentinny.
They have spaces for up to 4 people and will arrange transport once a date can be arranged.
Anyone wanting to take up the offer of a visit should contact the Community Council via email@example.com.
Ardentinny Community Council Survey Regarding the Dawn Fresh Fish Farm Proposal
The Community Council recently undertook a door to door survey of the village in respect of the Dawn Fresh Fish Farm proposals.
This survey consisted of one simple question are you for, against or neither of these regarding the project.
Every person eligible to vote and resided within the community council area was asked to vote
The outcome of the survey gives the Community Council the direction within which most of the village want to drive the dawn fresh fish farm project.
The survey itself was not associated with the AFF The Clyde or any other groups associated with this project.
The results for the survey can be seen below:
Total people eligible to vote in the Ardentinny CC area is 152 as at 16th May 2019
Total votes counted via door to door survey is 137 only 14 houses within the village had no one in at the time of the survey, some of these were holiday lets and some people just away at the time of the survey, every house where no one was in was visited a minimum of 2 times, these houses and votes were not counted in any way.
This equates to a 90.13% response rate from the whole village
Votes For – 17 or 12.41%
Votes Against – 101 or 73.72%
Neither for or against – 19 or 13.87%
Given the results noted above it is clear that the majority of the Community (73.72%) do not want the project to go ahead, The Community Council will now formally work with the AFF the Clyde Group and come up with an action plan to fight the proposal.
The first action will be to write strong letter of opposition To SEPA regarding the Dawn Fresh CAR Licence application
It is hoped that others including the AFF the Clyde group will also write letters opposing this, the letter will be displayed on the notice board, website and formally sent out to everyone on the mailing list as an update
If you would like to be kept up to date with the activities of the Community Council please email firstname.lastname@example.org and ask to be included in the mailing list.
If you would like to be removed from the list at any time, please email and let us know.
The community council will be completing a simple door to door survey over the next few days regarding the Dawn Fresh Fish Farm Project, the survey will give the Community Council the direction within which the majority of the village want to drive the dawn fresh fish farm project, this has nothing to do with the AFF or any other groups associated with this project, a simple yes no or neither is all that is required no personal data will be recorded all details will be published and mentioned at the next CC meeting.
One vote per person residing in the household over the age of 16 will be allowed, only people living permanently in the area will be allowed to vote.
Your help in completing the survey will be greatly appreciated
Official update from Dawnfresh to Ardentinny Community Council.
I just wanted to give you a quick update on the ongoing work with regards the proposed trout farm. We have not yet received the screening and scoping response from Loch Lomond and Trossachs National Park though I am expecting this through within the next fortnight. We are continuing to gather information on the proposed location and once we have the screening and scoping response it will give us an indication of ...the areas to put additional focus on when preparing the Environmental Impact Assessment.
The SEPA CAR Licence application which was submitted in December 2018 for the proposed site has reached the advertising stage and will be advertised in Fridays edition of the Dunoon Observer, the Edinburgh Gazette and on the SEPA website. The CAR licence process is completely separate to the planning process and its function is to decide whether the location, in this case Loch Long, has the carrying capacity for a trout farm of the size proposed based on current flow, bathymetry, seabed grabs and video survey and computer modelling of the worst case scenarios in the context of existing discharges into the loch. Sea lice treatments are regulated by SEPA under CAR and the consented quantities of medicines will be dependent on the carrying capacity of the loch.
The consultation period will be open for 28 days and is open to the public to comment.
I will be in touch once I have received the screening and scoping response but should you require any further information in the meantime please just let me know.
Dawnfresh fish farm proposal
As you are aware Dawn Fresh Fish Farming group are proposing to site a rainbow trout fish farm within the village boundaries. An initial planning application regarding environmental screening has been sent in to the national park for consideration. Details of this can be seen in other posts.
With this in mind, a group has been set up via individuals within the community who directly oppose the planned project. While the community council have to remain neutral till an official vote has taken place as per our objectives set out in the constitution please note the following information regarding the group.
The AFF - Against Fish Farming Group Has been set up with the specific intent to oppose the proposed siting of a Rainbow Trout Fish Farm off Ardentinny, The group currently led via Elaine Allan has already delivered a number of questionnaires throughout the village to gather data. This data, once collected will be published on the various web pages and notice boards and may well act as a pre-curser event for the community council to call an early official vote for the village giving the CC a firm direction to follow.
Residents of the village that have not yet returned the questionnaire or had it collected can return it directly to 6 Ardenfield or Finart Cottage or Crow Wood.
The group has also set up online petitions which are detailed below.
You may also wish to sign one of the petitions currently available locally as well as the online petition at https://you.38degrees.org.uk/petitions/against-fish-farming-aff-the-firth-of-clyde?just_launched=true
Against Fish Farming (AFF) the Firth of Clyde
Caged farming on land or water is innately cruel and severely damaging to our environment and the natural habitat of other species. Overcrowding leads to stress, disease and high mortality. Chemicals ineffectively used to treat disease and parasites such as sea lice, (which also transfer to wild fish populations) along with the large amounts of waste material (faeces) pollute the waters, destroy the seabed and biodiversity, wash up along the shore lines and beaches and give rise to health...
Facebook: just enter 'AFF - Against Fish Farming’ in the search bar to find us and more information.
Please note as already stated presently the community council must remain neutral on this matter and do not back any individual groups either for or against the proposal. It is up to individuals to vote one way or another, I would ask though that if you do receive questionnaires either for or against you do fill them in and return them so an accurate picture of the villages feelings towards this project can be gathered.
Ardentinny Community Council