From Monday 9 November 2020, marine finfish farm operators must apply to SEPA for permission to discharge medicine residues from wellboats. Licences will no longer be issued for wellboat discharges by the Marine Directorate.
All licences previously issued by the Marine Directorate will automatically transfer to us on Monday 30 November 2020 and be regulated under the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (CAR).
Due to the transfer, any Marine Directorate licences that require renewal between Monday 9 November 2020 and Thursday 29 April 2021 will be automatically extended until Friday 30 April 2021. Briefing documents from the Marine Directorate provide further information about the transfer of existing licences.
The changes outlined above were introduced by The Marine Licensing (Exempted Activities) (Scottish Inshore Region) Amendment Order 2020. They bring together the regulation of all discharges of medicine residues from marine finfish farms.
Proposed new discharges or changes to existing discharges
Operators wishing to discharge a bath treatment medicine residue must have a valid authorisation to do so.
Information on how to apply for a discharge permit can be found on the pre-appliction page. For existing farms, applications can be made as part of the normal licence variation process. CAR application forms and guidance are available from this website.
When we grant an application to discharge a bath treatment medicine residue, the permission to discharge will be incorporated into the finfish farm’s CAR permit.
The permit will provide that the discharge may be made from a wellboat at the farm or directly from the pens, subject to the quantity discharged in any period being within the limits specified in the permit.
The permission to discharge will not require periodic renewal. This is because CAR provides that we can vary or revoke permission at any time where we consider it necessary for the protection of the water environment.
Regulation of wellboat discharges
We will include discharges from wellboats in our normal compliance assessment work from the point of transfer onwards. This will include checking compliance with permit conditions and reporting on the volumes discharged and on compliance.
During 2022 and 2023, we plan to transfer all exiting marine finfish farms onto our new Finfish Aquaculture Regulatory Framework. This will involve replacing existing permits with our new finfish farm permit.
For farms with an existing permission to discharge bath treatment medicine residues, the new permit will provide the operator with the option to make the discharge directly from the pens or via a wellboat at the farm. The current limits on the quantity of medicine residues that can be discharged, including via a combination of discharges from a wellboat and directly from the farm’s pens, will not change. Once the new permit is in place, a separate wellboat permit will no longer be required and will be revoked.
In November 2022 SEPA adopted a temporary regulatory position statement which extends licences granted by the Marine Directorate authorising discharge of bath treatment medicines from a wellboat to the water environment pending incorporation of the corresponding conditions into SEPA marine pen fish farm permits.
Arrangements for notifications and data returns
We want to make it as easy as possible for operators using wellboats to discharge medicine residues to demonstrate compliance and for us to independently audit compliance.
As we take on the regulation of wellboat discharges, we will develop proposals in consultation with operators and other interested parties for strengthening how compliance is demonstrated and audited.
The use of wellboats for administrating bath medicines creates the potential for the sector to develop and adopt technologies for capturing and treating the residues to minimise discharges to the environment and decouple the size of discharges from the quantity of medicine used. We will work with operators to encourage and support such innovation wherever possible.
Enquiries should be submitted to SEPA's Water Permitting Team via email, using our online contact form.