Marine Harvest Scotland Farms Office, Blar Mhor Ind. Est., Fort William

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1 Marine Harvest Scotland Farms Office, Blar Mhor Ind. Est., Fort William PH33 7PT Sron, Loch Alsh 57 o N, 5 o W; E, N Atlantic Salmon Atlantic Salmon 22 pens 8 pens 20m square pens 2 Groups (7x2) and (4x2) 100m circumference circular pens 1 Group, in a 65m matrix 9,668m 2 6,370m 2 (less 3,298m 2 ) 65,376m 2 362,000m 2 Feed Barge -100T C-Cap No change proposed. Existing location 57 o N, 5 o W. Proposed location 57 o N, 5 o W Raft 14m x 7m No change proposed. Existing location 57 o N, 5 o W Proposed Location 57 o N, 5 o W. Moorings Rope Length Existing: East group:north 150m, East 100m, South 120m, West 64m West group:north 120m, East 64m, South 90m, West 65m. Proposed: North 300m, East 120m, South 100m, West 140m Ancillary Boat Moorings: No Change

2 2,335T (based on MSB of 1,600T) 1,600T application to be submitted to SEPA at the same time as the final planning application. Boat access from shore base at Kyle Pier no change proposed. The site currently has held a maximum biomass consent for 1300T since An application for a MSB of 1,600T will be made at the same time as the final planning application. EIA, for increase in biomass was submitted and approved in 2006

3 The Crown Estate The Crown Estate, 6 Bell s Brae, Edinburgh, EH4 3BJ 26 th June , , n/a 19, (595 cr) , th June 2009

4 Addendum to Environmental Statement In Support of Planning Application Proposed Expansion to Fish Farm Operations at Sron, Loch Alsh December 2009 Marine Harvest (Scotland) Ltd Blar Mhor Industrial Estate Fort William

5 Introduction. During the investigation of the proposed Marine Harvest (Scotland) Ltd site at Loch Alsh an area of reef was identified by an independent benthic analyst located at the north east corner of the cage group. The site at Loch Alsh falls within the SAC for lochs Duich Long and Alsh therefore on the advice of Scottish Natural Heritage, Marine Harvest (Scotland) Ltd has chosen to relocate the cages 130m to the west of the identified reef structure in order to minimise the potential impact of the proposed fish farm on the reef. It has also chosen to reduce the number of cages applied for to 8 initially with the intention to re-apply for an additional two cages at a later date. As the site layout and location have changed slightly Marine Harvest (Scotland) Ltd have produced this document to accompany the Environmental Statement, in which the sections and paragraphs of the ES which have been subject to change are identified and amended accordingly.

6 Section 2: Non-Technical Summary Description of Development Figure 1.2: Position of Proposed Cage Layout (red circles centers of cages; red solid line cage matrix; red dashed line extent of cage moorings) (NE Coordinate of cage group , ) Paragraph three Marine Harvest wishes to increase the maximum standing biomass (MSB) of the site from 1300T to 1600T and, in order to accommodate this, proposes to install 8x100m circumference circular pens which will be held in a (4x2) configuration. Currently, a 100T C- Cap feed barge is used at the Sron site there is no proposed change to this system. General Aquaculture Interaction with environment Paragraph two OSPAR (Oslo Paris Convention) Budget has been used to predict the amount of nitrogen discharged into Loch Alsh by the fish farming operation at Sron. The potential for nutrient enrichment was calculated using the Equilibrium Concentration Enhancement (ECE) equation, and this value was then expressed as a percentage of the water Environmental Quality Standard (EQS) set by SEPA. The ECE calculated for the proposed Sron site was 1.03ug/l, which is 0.61% of the SEPA EQS for nitrogen loading. Table 1 and 2 of technical report.

7 Paragraph three Loch Alsh is designated a marine Special Area of Conservation; a designation which also includes Lochs Duich and Long, and is for the marine reefs in the area. As part of the company s consolidation plan the site was tentatively selected for expansion; modeling footprints were generated to asses the fate of carbon, solids and medicinal residues; and farm configuration and location were adjusted to ensure minimal encroachment upon the marine reef interest. SNH recommended that the predicted depositional footprint of feed and faeces and medicinal treatments at the site should be assessed to determine if they are likely to impact on, or extend near to, the reef habitats. Previous broad-scale surveys carried out by SNH identified biotopes which are characteristic of qualifying reef habitat within the vicinity of the Sron site. In light of this, a benthic video transect survey was carried out to determine the proximity of reef habitat to the predicted footprint of the new cage groups. From transect 4 some species indicative of reef were suspected, however it was not possible to fully identify what species were present. MHS therefore commissioned a further study in order that the area in question could be further investigated. The study was undertaken by an independent consultant specialising in benthic ecology. The findings of this study showed that although there were some species indicative of reefs, the structure present in the video transect was an exposure of rock due to a change in bathymetry, as a result this structure was thought to be of low ecological value, This further survey is located at the back of this document in Attachment 10. SNH assessed that although the structure was of low ecological value it did still qualify as reef. As the area is designated as an SAC for reefs they were duty bound to conserve it. In light of this and on the advice of SNH Marine Harvest (Scotland) Ltd chose to relocate the cages 130m west of the original location in order to minimise any potential for impact on the reef. Section 3: Description of the Development 3.1 Physical Characteristics of the Development Figure 1.5: Layout of proposed cages (red circles centers of cages; red solid line cage matrix; red dashed line extent of cage moorings)

8 Paragraph two The site currently has permission for 22x20m square steel pens held in two groups ((7x2) and (4x2)) and a lease area of 170,000m 2. Marine Harvest wishes to increase the biomass of the site to 1,600T and, in order to accommodate this, proposes to install 8x100m circular circumference pens. The pens will be held in a (4x2) configuration in a 65m matrix. The proposed equipment will have a surface area of 6370m 2, which is 3,298m 2 less than the existing equipment, which has a surface area of 9,668m 2. Depths at the site necessitate long moorings and the proposed site modifications will require an increase in lease area to 450,000m 2 to ensure all moorings are within the designated lease area. Currently there is a 100T C-Cap feed barge is used at the Sron site this will be moved to the new location. An ancillary raft is also presently being used at the Sron site and the intention is to continue with this use for the new development. The expected FCR is 1.07:1, and the estimated feed input will be 3,341T over the 22.5-month production cycle, with an overall total salmon production of 3,148T. Access to the farm will continue to be from the shore base at Kyle Harbour. 3.2 Operational Characteristics of the Development Stocking (additional note) Marine Harvest (Scotland) Ltd intends to follow this application with a further application for an increase to the initially requested 2000T Maximum Standing Biomass in 10x100m cages therefore will stock the site with this in mind. Stocking will take place in March 2011 following a fallow period beginning in January Section 5: General Aquaculture Interactions with the Environment 5.1 Benthic Impacts Medicine Inputs, Paragraph Seven The stocking density being applied for is still15.7kg/m3 5.2 Water Column Impacts Paragraph Two The conclusions made in paragraph two for an increase to 2000T remain valid for 1600T Paragraph Three OSPAR (Oslo Paris Convention) Budget has been used to predict the amount of nitrogen discharged into Loch Alsh by the fish farming operation at Sron. The potential for nutrient enrichment was calculated using the Equilibrium Concentration Enhancement (ECE) equation, and this value was then expressed as a percentage of the water Environmental Quality Standard (EQS) set by SEPA. The ECE calculated for the proposed Sron site was 1.03ug/l, which is 0.61% of the SEPA EQS for nitrogen loading. Table 1 and 2 of technical report.

9 Section 5.4: Interaction With Wild Salmonids The Sea-lice Challenge Paragraph Five The conclusions remain valid for the reduced number of pens, all eight cages can be effectively treated over a period of three days therefore the potential for reinfection should be low. Section 5.5: Impacts upon species or habitats of conservation importance including sensitive sites Paragraph three The depositional footprints of feed and faeces around the proposed cage group can be found in the modeling report in Annex 1 of this document. Paragraph four SNH assessed that although the structure was of low ecological value it did still qualify as reef therefore as the area is designated as an SAC for reefs they were duty bound to conserve it. In light of this and on the advice of SNH Marine Harvest (Scotland) Ltd chose to relocate the cages 130m west of the original location in order to minimise any potential for impact on the reef. Section 5.7: Landscape and visual impact assessment It is the opinion of Marine Harvest (Scotland) Ltd that the conclusions reached in the visual impact assessment carried out for the initial application for 10x100m plastic cages remain valid for the revised application for 8x100m plastic cages located 130m to the west of the original location. New photomontages were prepared, taken from the same locations as those in Plates 1 8 in Part 2 of the Environmental statement to demonstrate this and can be found in Annex 2 of this document. Section 5.9: Cultural Heritage Please refer to the supporting document in Annex 3

10 Section 5.12: Traffic and Transport Paragraph Two Feed Deliveries - During the 22-month on-growing period a total of 3,341 tonnes of feed will be used, on average delivered in 80 tonnes volumes to the site, therefore requiring approximately 42 feed deliveries by boat. This averages out to be approximately 2 feed deliveries every month for the duration of the cycle. Paragraph three Harvest Traffic Fish are removed by well-boat typically in volumes of 75 tonnes. At this level it would require approximately 42 boat trips to remove all 3,148 tonnes which is expected to be produced over the next 22-month production cycle. This represents an increase of 8 harvesting boat trips. Harvesting would be expected to take place over an 11- month period with the number of boat trips expected to be, on average, 3 per month for the first 5 months and rising to approximately 5 per month for the remaining 6 months. Section 6: Assessment of Potentially Significant Negative Effects Section 6.1: Potential significant adverse environmental impact 1 Landscape and Visual Impact Assessment Marine Harvest (Scotland) Ltd has reviewed the Landscape and Visual Impact Assessment and provided new photomontages for the new position and layout of the cages (Annex 2). Marine Harvest (Scotland) Ltd has concluded that the original findings remain valid and unchanged; the reasons for this are the very slight nature of the change in cage position and the reduction in number of cages from 10x100m cages held in a 5x2 formation to 8x100m cages held in a 4x2 formation. Section 6.2: Potential significant adverse environmental impact 2 Nature Conservation Interests of National / International significance Mitigation Scottish Natural Heritage (SNH) assessed that although the structure was of low ecological value it did still qualify as reef therefore as the area is designated as an SAC for reefs they were duty bound to conserve it. In light of this and on the advice of SNH Marine Harvest (Scotland) Ltd chose to relocate the cages 130m west of the original location in order to minimise any potential for impact on the reef. Conclusions Marine Harvest (Scotland) Ltd has reviewed the findings of the assessment of the effect on reef habitats in the Lochs Alsh Duich and Long SAC and concludes that the results remain valid. The relocation of the cages to the west puts sufficient distance between the cage group and the marine reef to minimise any potential for impact on the reef.

11 Section 6.3: Potential significant adverse environmental impact 3 Impact on the wreck of the Port Napier Please refer to the supporting document in Annex 3

12 Part II OSPAR budget Technical Summary Table 1: Predicted levels of total nitrogen (N) waste released from existing & proposed Marine Harvest sites in the Loch Alsh system. Calculations are based on the budget by OSPAR (2004), and an expected FCR of All values are T/year. Total Feed Input T/yr Total N Input T/yr (6.4%) Total N in fish (3%) N lost into environmen t T/yr MSB T Productio n T/yr FCR N/Kg/yr Sron Present Ardintoul Present Sron Proposed To address qualitatively any concerns raised about the volumes of nutrients and organic waste produced from each site operated by Marine Harvest (Scotland) in the Loch Alsh unit, the Loch Alsh unit consists of the Sron site and the neighbouring Ardintoul site. The cumulative effect of nitrogen enrichment was calculated. It has been assumed that both sites approach their maximum standing biomass (MSB) at the same time, which is likely because the area is synchronised in its production, and it has been assumed that all the nitrogen will be advected into Loch Alsh at mean low water spring tidal levels. Additionally, the source rate includes both dissolved and particulate nitrogen; however the EQA is only set for dissolved available nitrogen, with the result that a higher nitrogen loading has been used for comparisons with the SEPA EQS. Therefore the ECE calculations provided represent a worst case scenario. As Marine Harvest also operates a site in Loch Duich, a cumulative nitrogen loading calculation has been carried out to determine the impact of expansion at all three sites on the water quality of the area, as both lochs are part of a single marine SAC. As a worst case scenario it was also assumed that all three sites will export the nitrogen into Loch Alsh. The total low water volume of Loch Alsh is approximately 1,134,000,000m 3 and the flushing time is given as 7 days. ECE = (S x M/Q) X 106 Where: S = Source Rate (kg N T production -1) M = Total Consented Biomass (T) Q = Flushing Rate (m3 yr-1) Flushing Rate (Q) = (loch volume/flushing time) x 365

13 Table 2: The Equilibrium Concentration Equivalent (ECE) from nitrogen loading calculated for the proposed sites in the marine SAC, expressed in relation to the EQS of 168 ug l -1 for available nitrogen set by SEPA. The nitrogen source rate used was kgn Tproduction- 1. Site MSB (T) ECE (ug/l) %ECE of SEPA EQS Sron Ardintoul Duich Total

14 Annexes Annex 1: Annex 2: Annex 3: Annex 4: Revised Modelling report Revised Photomontage Plates Attestation from independent benthic analyst confirming initial conclusions remain valid Alsh Revised Charts.

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