8 October
SOME THOUGHTS
(James Merryweather's personal considerations)
I visit the Highland Council's planning at least once a day, to see whether any new documents have been uploaded. I really want to see what the statutory consultees (SNH, SEPA, Marine Scotland etc.) have to say about the two applications that most interest the people of south Skye. There has been no activity whatsoever with Eishort 1 since mid July - nothing. Eishort 2 was stagnant between 30 July and 26 September when four amended documents arrived and then nothing further. The ROV seabed survey should have been accompanied by video footage from the ROV camera, but it has not yet been deposited with SNH. Therefore, SNH cannot properly assess the application.
Public consultation is due to start at the end of this week (see public announcements in the West Highland Free Press 9 Oct) and at this point we the public do not have access to some vital material we need in order to assess properly these two applications which, if passed, will have very significant impacts on our landscape, lifestyle and local wildlife that is among the most important in Britain. We do have the Environmental Impact Assessment, which is a pretty dreadful piece of work and the ROV report, which is utterly appalling with no accompanying video footage, which judging by previous performances by Marine Harvest and Hjaltland, is pretty well guaranteed to be unbelievably lousy too. In case you missed it, this is how I described the Hjaltland Loch Slapin videos (and ditto applies for Loch Snizort East, another Hjaltland proposal targeting north Skye):
It is evident from observing the behaviour of the ROV that:
a. It did not arrive at the seabed before filming began.
b. It spent much of its time looking upwards or from too great a height (shows blue rather than brown) or occasionally examining its own superstructure and umbilicus.
c. When it was actually filming the sea bed it undulated wildly, in such a way as to make the viewer feel quite seasick.
d. It often travelled so rapidly that the viewer is unable to keep up and make observations.
e. The compass – screen centre – and the film itself (on the rare occasions when the seabed was visible) showed it spent much of its time revolving, indeed spinning, sometimes well in excess of 360º, rather than following the straight line which defines a transect.
f. It frequently crashed into the sea bed, generating dense clouds of sediment that totally obscured the scene for minutes at a time.
g. When the sea bed could be inspected, for much of the time any biological entities that came into view were indistinct or out of focus, or flashed by too rapidly.
Having read the Highland Council's Decision Document that itemised the reasons Hjaltland's Loch Slapin application was rejected it seems obvious to me that the same refusal criteria should apply to the application Eishort 1, the site for which is situated only a matter of a couple of kilometres round the corner south of Suisnish with a similar Burrowed Mud seabed (priority habitat) to be considered. It is also only 2 km away from extensive maerl beds, seagrass beds and other priority habitats. The two sites are so close and so similar that refusal of Eishort 1 must surely be a foregone conclusion – or will Hjaltland withdraw at the eleventh hour? It has been known: Marine Harvest and Loch Slapin.
We must remain diligent re Eishort 1, but I suspect that Eishort 2 will become the focus Hjaltland’s south Skye lochs attention and they will not take refusal of that lying down. If refused, the developer has the right of appeal (presumably to the Scottish Government) whilst we, the public, have no such right. However, if they do appeal, we will (won't we?) register our disapproval anyway, whether we are ‘allowed to’ or not.
Eishort 1 should be relatively easy to counter, simply by methodically referring to all the refusal criteria laid down in the Council’s Decision Document on Hjaltland’s Loch Slapin application plus introducing Loch Eishort’s particular environmental-ecological qualities, which are prodigious. Eishort 2 between Tokavaig and Tarskavaig is another matter. There is no next-door refusal to ‘copy’ criteria from and the site is offshore of land more off the beaten track, though nevertheless it's a stunningly beautiful place with a wonderful, if hard-going, seashore. The nearest residences are quite close by, but with a hill in between, so Tarskavaig might assume that a fish farm there will cause little disturbance. That might indeed be so. However, residences across the loch at Glasnakille, Drinan and Kilmarie will have a grandstand view, plus (I speculate, not without cause/experience) the constant, distant hum of generators powering underwater lights and the feed barge, sound which, particularly on calm days, will cross the loch with ease, perhaps amplified by the cliffs. Add to that visits by noisy (we know from Loch Alsh) well boats that visit sometimes for days on end, anchored with engines and lights on constantly. A noteworthy quality of this loch system is its wonderful peacefulness.
The sea bed beneath the Eishort 2 site and nearby is less well studied than at the other sites, so it will be difficult to raise objections citing recorded evidence of ecological quality. The SNH survey provided some tantalising glimpses, but not a full assessment of this area. That means that we must emphasise the Precautionary Principle (from the 1992 Rio Declaration to which the UK is a signatory) which states that if you don’t know what is there, then development must not proceed until proper biological surveys have been carried out. Judging from the inept science and appalling presentation of their previous environmental reports and considering their coverage is restricted to the fish farm site, Hjaltland’s own survey will be entirely unsuitable for this purpose (if we ever get to see it).
We will have to insist that extensive seabed surveys are carried out before planning permission can even be considered and that it should not be granted until all local environmental safety standards are assured and also that we can be certain that sedimentation on and eutrophication of priority habitats not very far away – for instance the maerl and seagrass beds in Tarskavaig Bay – will not occur. A claim that conventional modelling procedures have been conducted by SEPA should be treated with circumspection and questions which we might hope would improve clarity, if we can understand what they tell us.
So, I cautiously predict that Hjaltland’s plans to develop Eishort 1 will, in one way or another, be dropped. [Also cautiously, I have been informed - 10 Oct - that might not be so, but that was from someone who may tell me only facts of the moment and no helpful hints.] Then we might expect them to throw everything they’ve got at Eishort 2 and we will have to make sure we are fully informed and that our consultation responses are well-constructed, concise and numerous. Quite how we will manage that will be very dependent upon all of the documents – from the applicants and the statutory consultees – becoming available to us for appraisal. If they are nor there in time for us to write our letters before the closing date (7 November) we will have to write additional letters. But we must not give up until it's all over – decision dates are predicted to be 29 and 30 November.
If both go ahead, we will all have two different letters to write in separate consultation, unless we can arrange special dispensation for the unusual situation of two separate consultations for two applications for one loch occurring at the same time.
We hope to have many people join us in Tarskavaig Communities Hall at 7.30 pm on 21 October for briefing and discussion chaired by Sleat Community Council.
