COMMENT LETTERS
in the second consultations: Eishort 2 & Eishort 1
We have posted these letters here so that they may act as a source of information and inspiration for anyone else wishing to submit their own comment letters. By all means use the ideas therein, but please write them in your own style. You'll find some assistance/advice about deficiencies in the two revised seabed survey reports down the page, below the letter links.
James Merryweather
EISHORT 2
EISHORT 1
Roger Cottis
EISHORT 2
EISHORT 1
Eileen Armstrong
EISHORT 2
EISHORT 1
Niall McKillop
EISHORT 2
EISHORT 1
SLEAT COMMUNITY COUNCIL
E-mail letter to contibutors to previous consultations
EISHORT 2
EISHORT 1
HJALTLAND PLANNING APPLICATIONS EISHORT 2 & EISHORT 1
SECOND CONSULTATION – SUMMARY OF CRITICISMS
As we’ll all remember, after much head scratching and hard work, in November 2014 we contributed our own viewpoints in comment letters submitted to the Highland Council’s planning department. Many of our criticisms concerned the quality of Hjaltland’s Environmental Impact Assessment (EIA) which included a risibly infantile and incompetent seabed surveys. After a long silence, way beyond the date for decision, new seabed survey reports arrived on the ePlanning website, confirming what we had begun to suspect: that the planners had ordered Hjaltland to repeat some of their EIA work.
Two revised seabed surveys were posted and unfortunately that is all we can expect. Fortunately a new consultation was opened so that the public might comment on this new material. We do not have long to attend to this consultation, the closing date for which will be 2nd October 2015. Members of the Scottish Salmon Think-Tank (the new name of our local Sleat group since October 2012 – you know us: Rob, Eileen, Roger and James) have begun to submit their comments in this new consultation, and for everybody’s guidance they are being published on the SST-T website page as soon as they have been sent in so that others may consult them for information.
In addition, we provide a summary (below) of the points we think should concern the planners with regard to Hjaltland’s latest inept attempt to prove that new fish farms in Loch Eishort will have little significant environmental impact. [Actually, they haven’t mentioned such an idea, having never got further than copying and pasting new but bad data into their previous reports, without any discussion or recommendations whatsoever!]
This consultation is only about those two seabed surveys and associated documents (which may mostly be overlooked because they’re just padding). If you wish to see the video footage taken by a camera mounted on a small remotely-controlled submarine (ROV), please ask. That’s all they used for data collection and, as the results show, the method was woefully inadequate. The trouble is that our government sponsored representatives who advise the planners will likely approve this appalling ‘science’, so it will be up to the public to play their proper role for them. Mind you, to their credit, SEPA very quickly wrote in to disapprove, at least temporarily, but our criticisms need to be well-argued, fact-based and accurate … and fearless.
Here are some of the reasons we at SST-T think the two Loch Eishort seabed surveys failed adequately to describe the seabed in the vicinity of the proposed fish farms and entirely failed to suggest mitigation for predictable (some would reasonably say inevitable) severe environmental impacts.
- ROV video footage did not display GPS co-ordinates, so there is no way we can tell where the transects were situated, or that their trajectories were not fabricated (as in the previous, rejected seabed surveys).
- Although a line was laid out on the seabed and the ROV appeared to follow it, data (presence/abundance of animals) were haphazard, poorly identified and gathered within an undefined area. In fact all they were doing was naïvely having a general look around, not carrying out a properly structured survey at all. That’s not scientific.
- Frequently, the ROV’s propeller disturbed sediment so that nothing could be seen anyway and data could not be gathered.
- Structure of the entire study (as reflected by the meagre report) was not conventionally scientific, indeed it was approximate, muddled, erroneous and inadequate.
- The report structure was a complete muddle and text did not tell the reader what section titles announced. The summary did not summarise, but was a kind of cursory, incomplete introduction. Some of the other sections either contained the obvious or irrelevant, or did not describe what their titles suggested they should.
- Results were presented as tables that contained inadequately collected data containing many errors. The scoring system used (as already strongly criticised in previous consultations, yet not amended) was utterly useless – for discussion see James Merryweather’s letters (links above).
- The results – meaningless though they were – were not analysed.
- The reports contained no discussion of the results.
- The reports did not present the reader or the planners with any conclusions based on the survey’s findings.
- The reports did not consider what environmental impacts would result from the installation of fish farms in Loch Eishort (other than mention and map the AZE – SEPA’s accepted Allowable Zone of Effect – which is the area of seabed that would be totally changed for the worse with a fish farm above).
- The reports did not consider or make any suggestions for mitigation of environmental impacts of a fish farm at either site or both ... which is the whole purpose of the EIA exercise!
- Flawed experimental design and implementation plus bad results with no analysis or discussion created two meaningless and, therefore, useless reports upon which nobody could construct mitigation of environmental impacts and the planners could not reasonably arrive at a decision.
- Because the reports are almost identical, our comments too can’t help being similar. If you note any dissimilarities between the two sites, please try to insert a little difference.
- Even if that is not possible, it is essential that the survey of each of the two sites be considered separately and that two site-specific comments should be submitted.
- Thank you for playing a role in this consultation. It is likely to be our last chance at objecting to Hjaltland’s industrial plans for the south Skye lochs …
- … but that was what we thought last November, and it seems that after we had our say last time the Highland Council’s planning officers might actually have taken into account our informed public opinion. That’s very gratifying.
- When you’ve finished dismantling the two reports, please end with a paragraph reminding the planners that net-cages should be replaced with closed-containment tanks. The more often we say this, the deeper the idea will penetrate into the planning psyche. We at the SST-T are doing our best to take this message to the Scottish Government. (watch this website) A new company in Canada called Sustainable Blue has just begun supplying supermarkets with tank-reared Atlantic salmon, so we know that closed containment can be done.
AFTERTHOUGHTS
I still have the stark impact of Duncan MacInnes’s impassioned contribution at last year’s meeting in Tarskavaig Hall ringing in my ears. It was so simple an idea, but until he so eloquently expressed it, we’d never thought of it: “We don’t want fish farms in our lochs and we never asked for them”. The salmon aquaculture industry simply came and attempted to take over – uninvited and unwanted – confident of minimal competent opposition to their applications for planning permission. We hope they were mistaken.
So now another basic idea has crossed my mind: Public consultation is a fine privilege of democracy, but how can people like us be expected to send in competent comments on a matter about which we have (had!) little or no knowledge. The aquaculture companies know exactly what they need to do to set up fish farms – it’s what they do – but we have all specialised in and have knowledge of other subjects (of immense diversity), but not fish farming and the business-political shenanigans played out by fish farm companies. OK, we learnt it all as fast and as best we could, but at what cost to our time, patience, personal lives and bank accounts?
The bottom line is that, with outcomes loaded in favour of aggressive outsiders hell-bent on despoiling our homeland for their selfish profit, it’s simply not fair on local people and our environment, a point worth communicating to the planning authority, along with the best critiques we can contrive and the sincere request that our community voice should be heard.
