Planning Application 13/01494/FUL - Loch Kanaird Eastern Side Of Isle Martin
Colin Wishart Esq.,
Countryside, Heritage and Natural Resources Section,
Planning & Development Service,
Inverness IV3 5NX
Dear Mr. Wishart,
We wish to lodge a formal objection to the above planning application by Wester Ross Fisheries for an expansion of their salmon farming operation in Loch Kanaird. While we support those who have opposed this application on the grounds that it is far too close to the mouth of a river with a population of migratory wild Atlantic Salmon and sea trout we have a very specific objection which I hope you will recognise and uphold.
This application fails to meet the legal requirement under the Animal Health & Welfare (Scotland) Act 2006 which obliges salmon farmers to protect their stock from predators. Under the Animal Health & Welfare (Scotland) Act 2006 salmon farmers must not only protect their stock from physical attack by seals, they must also protect them from the stress and fear caused by allowing seals or other predators to come close to the salmon.
Shooting seals under Government license does meet the legal requirements of the Animal Health & Welfare (Scotland) Act 2006 as it is impossible to shoot all seals which approach the salmon cages. To do so shooters would have to be able to shoot safely and accurately at night and in all weather conditions including fog and storms. They would also have to be able to shoot an unlimited number of seals as, should they reach the quotas allowed under their Government license, they could no longer protect their stock from the attention of seals. Acoustic deterrent devices are not 100% effective in keeping seals away from salmon farms.
The only way salmon in a marine cage farm can be fully protected from the attention of seals is by the proper installation and maintenance of high-strength, tensioned predator exclusion nets fitted in such a way as to ensure seals cannot approach the inner cage nets.
We ask you to refuse this application on the grounds that by failing to include predator exclusion nets in the farm design the applicants cannot meet their legal duty to protect the welfare of their stock under the Animal Health & Welfare (Scotland) Act 2006.
John F. Robins,
Save Our Seals Fund