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Permit conditions and explanatory notes

One Planet Prosperity

SEPA is transforming the way we regulate by moving from a single site approach to sector-based solutions.  We have two simple aims for every sector we regulate:

  • every business fully meets its compliance obligation;
  • as many as possible go beyond compliance.

One of the things we are doing to support a sectoral approach is to reform our environmental authorisations.  We are developing permits which will be built around a set of principles:

  • Permits will be clearer;
  • Permits will be enforceable;

Permits will be written in simple, plain English that everyone can understand, from the general public to the Sheriff in the Court;

Permits will contain the minimum number of conditions to achieve the environmental outcomes of preventing harm; preventing incidents and accidents; and ensuring resources are used sustainably;

Permits will put the responsibility for environmental management on to the operators of the permitted activity.

Our simple, outcome focussed permits are part of One Planet Prosperity – our Regulatory Strategy

Legislative background and Permits

The Water Framework Directive (WFD) establishes a legal framework for the protection, improvement and sustainable use of the water environment across Europe. It places a number of requirements on member states including the prevention of deterioration and enhancement of the status of aquatic ecosystems in addition to the promotion of sustainable water use.

The WFD became law in Scotland at the end of 2003 through the Water Environment and Water Services (Scotland) Act 2003 and in April 2006 through the Water Environment (Controlled Activities) (Scotland) Regulations 2005. The latter was replaced with the Water Environment (Controlled Activities) (Scotland) Regulations 2011 (“the Regulations”, also known as CAR).

CAR sets out the regulatory framework for achieving some of the aims of the WFD in Scotland. It imposes a duty on any person carrying out a CAR authorised activity to take all reasonable steps to secure efficient and sustainable water use. It also allows SEPA to protect the water environment from harm via its authorisation process.

SCHEDULE 1: THE AUTHORISED PERSON AND ACTIVITY

 

1.1 Authorised Activity

1.1.1 The Authorised Activity is the discharge to the water environment of fish excreta, uneaten food and other substances as listed in this permit resulting from the operation of a marine pen fish farm.

The Authorised Activity is terminology that is used in the Environmental Authorisations (Scotland) Regulations 2018 (EASR). For the purposes of this template it is defined as the Controlled Activity under CAR.  This condition authorises the specific activity that may be carried out. It means that any activity not listed in this condition is unauthorised and therefore a breach of the Regulations.

 

 

1.2 Duty of Authorised Person

1.2.1 The Authorised Person must ensure compliance with all the conditions of the permit.

The Authorised Person is terminology that is used in EASR. For the purposes of this template it is defined as the Responsible Person under CAR. The condition places the responsibility for compliance with the permit conditions on the authorised person, regardless of whether an employee or sub-contractor is carrying out the authorised activity.

SCHEDULE 2: MARINE PEN FISH FARM DESCRIPTION

 

2.1 Fish species

2.1.1 Only [species] may be farmed at the site.

Different species of fish have different metabolisms and this affects the amount and types of waste a fish farm produces. It is important that SEPA applies controls to the species farmed at the site. In most cases this will be Atlantic salmon (Salmo salar) or rainbow trout (Oncorhynchus mykiss) although other species, such as cod and halibut, could be farmed in Scotland. 

2.2 Maximum Weight of Fish

2.2.1 The maximum weight of [species] held on site at any one time must not exceed [X] tonnes.

This condition controls the scale of the discharge from the fish farm. The figure used in each permit is site specific and is set at a level to prevent a breach of environmental standards.

Only the species which is being grown for cultivation is included in conditions 2.1.1 and 2.2.1. Some farms use ‘cleaner fish’, such as wrasse, which are kept in the same pens as the cultivated fish in order to feed on any sea-lice which may be present.

SEPA encourages the use of non-medicinal strategies to control sea-lice and ‘cleaner fish’ are an important part of these strategies at many fish farms. We do not currently control the number of cleaner fish present at fish farms. We will continue to monitor the use of cleaner fish and if there is evidence that they have a significant contribution to loading of waste discharged to the water environment we may revise our position.

2.3 Fallow Period

2.3.1 There must be a minimum period of [42 consecutive days] / [6 consecutive weeks] between every production cycle during which no [species] shall be kept on site.

Fish are typically grown at sea over a 24 month period. This condition requires the fish pens to be completely emptied of the commercial species for a set amount of time during every production cycle.  The purpose of this condition is to break the life cycle of sea lice and therefore reduce the amount of medicines which are discharged from the site.

The 42 day / 6 week period in the permit template is considered to be the minimum amount of time required to prevent sea lice re-infestation. The fallow period may be increased or decreased depending on the nature of the site.

It does not currently apply to any cleaner fish which may be present at a fish farm. SEPA recognises that cleaner fish are an important part of non-medicinal sea lice management strategies.  We will monitor the impact of retaining cleaner fish at fish farms throughout fallow periods and if there is evidence that retaining them means that sea lice numbers do not reduce to levels as we would expect we may revise our position.

2.3.2 SEPA must be notified within 14 days of the site being stocked

2.3.3 SEPA must be notified within 14 days of the site being fallowed.

The conditions are necessary to provide an up to date record of the sites that are operational and to ensure that sites are being appropriately monitored for environmental impact.

2.3.4 The site must be operated in accordance with the Management Agreement concluded between [A], [B] and [C], reference [X], dated [Y].

Please note that this is an optional condition which will not be required for most fish farms.

Management Agreements are allowed under CAR as long as they are properly referenced. They are used where different operators with farms in a single waterbody are required to work in partnership to resolve an environmental problem.  An example in a marine fish farm context would be for operators within a sea loch to coordinate fallow periods to break the life cycle of sea lice to minimise medicine use and therefore the impact of medicines on the environment.

The Management Agreement will be agreed amongst different authorised persons and will be referenced in the permit.  This means that it becomes a legal requirement which can only be changed by applying to SEPA to vary the permit.

2.4 Pen Configuration

2.4.1 The fish pens must be configured as set out in Table 1.

Table 1 Pen configuration
Number of pens <<Enter Value>>
Circumference of pens  <<Enter Value in metres>> m
Depth of nets  <<Enter Value in metres>> m
Number of different pens groups  <<Enter Value>>
Number of pens in each group  <<Enter Value>>
Number of pens in row 1  <<Enter Value>>
Number of pens in row 2  <<Enter Value>>

(Optional, delete if not required) Gap between each pen

 <<Enter Value in metres>> m

(Optional, delete if not required) Gap between pen groups

 <<Enter Value in metres>> m

2.4.2 The Authorised Location of the fish pen group is within an area delineated by the [colour] line in Figure 1* and bounded by the pen corner buoys located at the following National Grid References (NGRs):

  1. NGR [1 and appropriate cardinal point, e.g. NW]
  2. NGR [2 and appropriate cardinal point, e.g. NE]
  3. NGR [3 and appropriate cardinal point, e.g. SE]
  4. NGR [4 and appropriate cardinal point, e.g. SW]

As part of the application process, operators will propose the size and location of the fish farm following the initial set of assessments carried out at the pre-application stage.  SEPA will then use this information in computer models to predict the area of environmental impact that the fish farm is likely to have.  If the models indicate that the proposal is acceptable, SEPA will control the location of the fish farm in order to ensure that the impact from it behaves in the way that the modelling predicted.

The details contained in Table 1 and Figure 1* will be different for each fish farm but will include information relating to the size of pens and the grid references at each corner of the site for SEPA to ensure that the farm is in the correct location.

*Please note that Figure 1 is not provided here. It will be specific to each site and will be provided at the application stage for inclusion in the permit.

2.4.3 The pen corner buoys must not be located at a distance greater than [XX] metres in any direction from the NGRs listed in 2.4.2.

SEPA recognises that marine fish pens are subject to external forces such as tides, currents, wind and waves and that this means their positions can shift periodically. To account for this, the condition allows a degree of movement of the fish pens.

SCHEDULE 3: MEDICINE USE

 

3.1 Medicine Minimisation

 3.1.1 All reasonable steps must be taken to minimise the discharge of medicine residues.

The introduction to this document explains that the WFD, the European directive which underpins environmental regulation of the water environment in Scotland, contains a requirement for the sustainable use of the water environment. This is important to ensure controlled activities do not unnecessarily increase the risk of breaching an environmental standard or use more environmental capacity than is needed. The minimisation of medicine residue discharges minimises the demand placed on the environmental capacity of the marine environment. This condition helps to ensure the protection of the water environment through sustainable water use.

3.2 Medicines and Chemical Use

3.2.1 Only those medicines and chemicals specifically authorised in this permit or in [the Permitted Substance List (the PSL) (REF)] OR [the Permitted Substance Working Plan (the PSWP) (REF)] may be discharged to the water environment.

The sea lice medicines named in site Permits have specific limits applied and are subject to assessments during the application stage to ensure that environmental standards will be met and that the environment will be protected.

The PSL and PSWP are lists of chemicals and medicines which SEPA has assessed as having low or no environmental risk provided they are used in accordance with the manufacturer’s instructions.  Operators must report the amount of these chemicals they use and this information will be used to help inform ongoing reviews of these lists.

Only those medicines and chemicals named in the permit or the PSL/PSWP can be discharged to the water environment (subject to the appropriate conditions). Any other medicine or chemical that is discharged is considered to be unauthorised and a breach of CAR.

3.3 Permitted Substance List OR Permitted Substance Working Plan

3.3.1 All medicines and chemicals named in [the Permitted Substance List (the PSL) (REF)] OR [the Permitted Substance Working Plan (the PSWP) (REF)] must be used in accordance with the limits specified in [the PSL] OR the [PSWP].

The PSL and PSWP are lists of chemicals and medicines which SEPA has assessed as having low or no environmental risk provided they are used in accordance with any stated limitations in the PSL or PSWP. These limitations are set by SEPA and may be specific to each substance or may state that substances must be used according to the manufacturer’s instructions. Operators must report the amount of these chemicals they use and this information will be used to help inform ongoing reviews of these lists.

3.4 Bath Sea Lice Medicines

3.4.1 The medicines in Table 2 must only be discharged following treatment of the fish within an enclosure fully separated from the water environment.

Table 2: Permitted Medicine - Bath
Medicine name

Active ingredient

Salmosan, Salmosan Vet or Azasure Azamethiphos
AMX or ALPHAMAX Deltamethrin

3.4.2 The enclosure in which fish are treated with [Medicine Name] must be no more than [X] % of the full pen volume.

3.4.3 The enclosure in which fish are treated with [Medicine Name] must be no more than [X] % of the full pen volume.

In order to minimise the use of sea lice medicines and maintain sustainable use of the water environment, SEPA places controls on how some medicines must be administered.  These conditions state that fish pens which are being treated must be separated from the rest of the water environment. This is normally done by enclosing the pen in an impermeable barrier, such as a tarpaulin.

3.4.4 The quantity of medicines in Table 2 used must not exceed:

[XXX] grams of azamethiphos in any [XX hour] period.

[XXX] grams of deltamethrin in any [XX hour] period.

Before allowing the discharge of a medicine to the water environment, SEPA assesses the environmental risk posed by each substance. This assessment considers various aspects such as the toxicity, chemical properties and formulation of each medicine. SEPA sets limits on the amount of bath sea lice medicines that can be used. This is done to safeguard environmental standards and ensure that the water environment is protected. Each bath medicine will be given a limit which can be discharged over a set time period.

3.4.5 The medicines in Table 2 must not be combined with each other or with any other substance or compound during any treatment in a single pen.

3.4.6 When multiple pens are being treated at the same time, only one of the medicines in Table 1 may be used at the site.

3.4.7 The medicines in Table 2 must not be discharged within 24 hours of the discharge of any bath treatment medicines from a wellboat at the site.

SEPA’s assessments of the medicines which can be used at fish farms are based on known properties such as the formulation of the product to be used, its specific chemical properties and toxicity in the water environment.  Combining sea lice medicines with each other or with other substances may alter the properties of the medicines and produce unintended adverse environmental impacts.  These conditions prevent any unintended impacts and ensure the water environment is protected.

3.5 In-feed Sea Lice Medicines

3.5.1 Any treatment with the medicine in Table 3 must be carried out over a 7-day period.

Emamectin benzoate, which is administered to fish in the form of medicated feed pellets, behaves in a different way to bath sea lice medicines. It is absorbed by the fish and then excreted over a period of around 200 days. The residues from this process then sink to the seabed along with any uneaten food. The emamectin benzoate breaks down slowly with a half-life of around 250 days.

Table 3: Permitted Medicine – in-feed
Medicine name Active ingredient
Slice or Quinafish Emamectin benzoate

This means that emamectin benzoate residues persist in the environment for as much as 5 years. It is highly toxic to aquatic life but during the trials of the product the impacts could be limited to acceptable levels providing it was administered under certain conditions. The first of these conditions is that a single treatment of emamectin benzoate must be carried out over a set period of 7 days.

3.5.2 Subject to 3.5.3 and 3.5.4, the total quantity of the medicine in Table 3 used in any treatment must not exceed 50 micrograms per kilogram of [Atlantic Salmon OR Rainbow Trout] treated per day.

The normal dosing rate for emamectin benzoate is 50 micrograms of medicine per kilogram of fish per day over a 7-day period. This was the dosing rate used in the trial of the product. If there were to be a significant deviation from this limit it would result in an unpredictable impact on the environment and therefore an increase in environmental risk.

3.5.3 Subject to 3.5.4, the total quantity of the medicine in Table 3 which may be used in any treatment may be increased to a maximum of 60 micrograms per kilogram of [Atlantic Salmon OR Rainbow Trout] treated per day, where it has been authorised in writing by a registered veterinarian.

On some occasions, a registered veterinarian may make an assessment that fish health issues mean that a higher dosing rate is required. This condition permits dosing at an increased rate provided that this does not have a significant adverse impact on the environment. Operators are required to notify SEPA of their intention to treat at an increased dose prior to administering the medicine, and SEPA will assess each of these notifications to ensure that the environmental standard is not breached (see condition 3.6.2 for details).

3.5.4 [EXISTING SITES ONLY - Delete if not required] Any treatment of the medicine in Table 3 must not exceed the maximum environmental quantity of [XX]g.

As previously stated Emamectin benzoate breaks down very slowly in the environment and therefore there is a high risk that repeated doses of the medicine would exceed the environmental quality standard at the edge of the mixing zone (see condition 4.2.1). In order to prevent this SEPA sets a maximum environmental quantity which is the maximum residual quantity of Emamectin Benzoate in the environment at any one time which if complied with will meet the environmental quantity standard at the edge of the mixing zone. 

This means that prior to treating the fish the operator must notify SEPA who will assess whether the quantity of medicine proposed will exceed the maximum environmental quantity (see Condition 3.6.2). In order to assess whether the MEQ will be exceeded SEPA will take into account previous treatments. If the proposed dose is likely to exceed the MEQ SEPA will inform the operator to revise the quantity of dose.

To help operators plan their treatments SEPA will provide them with a copy of the ‘Slice Re-treatment’ calculator for their site.

 3.5.5 [NEW SITES ONLY - Delete if not required] The maximum quantity of the medicine in Table 3 which can be used in a treatment must not exceed<<Enter Value>>g.

 3.5.6 [NEW SITES ONLY - Delete if not required] Following a treatment of the medicine in Table 3 as outlined in 3.5.5, no further treatments of the medicine in Table 3 may be carried out for 5 years.

For new fish farms the new environmental quality standard will apply which is much tighter than the existing standard. This means that the maximum environmental quantity (MEQ)  will greatly reduce and in practical terms to stay within the MEQ the operator will only be able to effectively treat the fish once every fish years. SEPA will set the maximum quantity of medicine that can be used in one single treatment (3.5.5) and restrict its use for another 5 years (3.5.6).

3.6 Notification of Medicines Use

3.6.1 SEPA must be given the information in Table 4 no fewer than 2 working days before using any medicine in Table 2.

Table 4  Bath Medicine Notifications
Medicine type Information required
Bath medicines Amount of medicine to be used
Amount of active ingredient to be used
Number of pens to be treated
Proposed start and end date of treatment

3.6.2 SEPA must be given the information in Table 5 no fewer than 5 working days before using any medicine in Table 3.

 Table 5  In-Feed Medicine Notifications
Medicine type Information required
In-feed medicines Biomass at start of treatment
Biomass at end of treatment
Amount of medicine to be used
Amount of active ingredient to be used
Proposed start and end date of treatment
Veterinary authorisation, if applicable

 

 

SEPA requires the above information before treatment is carried out to allow audits of medicine use and to intervene if the operator’s intended use is likely to breach permit conditions. This is of particular importance for in-feed medicines where due to slow breakdown in the environment the quantity proposed by the operator may exceed the maximum environmental quantity (Condition 3.5.4). In those circumstances SEPA would intervene to require compliance. Medicine use information is published by SEPA and partner organisations.

 

 

SCHEDULE 4: SEABED STANDARDS

 

4.1 Biological Seabed Standards

4.1.1 The seabed at any point immediately under the outer edge of any pen must contain a minimum of 2 species of re-worker polychaete worms with a combined abundance of more than 1,000 individuals per square metre.

This condition ensures that the waste from the fish farm does not accumulate on the sea bed underneath the edge of the cages to levels that no longer allow biological processes to function.The ecology present in the seabed help breakdown and assimilate the wastes. This standard has been derived by SEPA and it ensures that there will always be a sufficient number and diversity of organisms present in the seabed underneath the edge of the fish pens. 

This standard may not be applicable where the substrate underneath the fish farm is dominated by rocks and stones. In these circumstances which will be highlighted during the application process SEPA will develop an alternative condition to protect the seabed

4.1.2 The seabed around the fish farm at the boundary of an area of <<Enter Value>>m² (the “mixing zone”) must meet as a minimum an Ecological Quality Ratio (EQR) of 0.64 IQI at any time.

Our regulatory framework limits the maximum area of the mixing zone. The limit is equivalent to the area lying within 100 metres of the pens in all directions. This condition ensures that the impact from the fish farm is contained to the mixing zone. The environmental standard of EQR of 0.64 IQI is at the boundary of the mixing zone is defined as “Good” in the 2014 Standards Directions.

IQI is a system which assesses the ecology of the seabed by looking at the different kind of organisms that live there and assigning them a numeric score based on a number of factors, including their tolerance to different kinds of pollution. Physical samples of sea bed sediment are collected, along with the organisms which live there. These organisms are then counted and sorted into groups before a calculation is used to obtain the IQI score. IQI scores range from Poor to High

 

4.2 Chemical Seabed Standards

4.2.1 [NEW SITES ONLY] Emamectin benzoate concentrations must not exceed 12 ng/kg (dry weight) in the seabed at the boundary of the mixing zone.

4.2.2 [EXISTING SITES ONLY] Emamectin benzoate concentrations must not exceed [XX] ng/kg in the seabed at any point 100 metres from the outer edge of any pen.

Some medicines are incorporated into fish food (“in-feed medicines”). This medicated food is fed to the fish over a number of days and residues of the medicines are excreted by the treated fish. The medicine residues in the excreta and any uneaten medicated food sink to the seabed alongside other organic waste. These residues can then accumulate on the seafloor to levels that are toxic to seabed organisms. The environmental quality standard for emamectin benzoate (an in-feed medicine) has been set at the edge of the mixing zone in order to meet ‘Good Status’ standards.

SCHEDULE 5: ENVIRONMENTAL MONITORING

 

5.1 Seabed and Water Monitoring Plan

5.1.1 A Seabed and Water Monitoring Plan (SWMP), written in accordance with [GUIDANCE REF] must be submitted to SEPA no later than [DATE]. 

Please note – this condition will only be used only for existing sites. For new sites, SWMPs must be provided at the application stage, following the initial assessments carried out during pre-application.

5.1.2 Monitoring must be carried out in accordance with the Seabed and Water Monitoring Plan (SWMP) [name, reference number, version number, date].

Operators are responsible for ensuring that the wastes discharged from fish farms do not have a significant adverse impact on the water environment.  In order to assess this, they will be required to collect and analyse environmental samples taken from the seabed and water in and around the fish pens. 

In order for SEPA to have confidence in the results the samples must be collected, handled, stored and analysed appropriately.  To ensure that this happens, operators must produce a monitoring plan, which must be written in accordance with SEPA. The monitoring plan will be assessed by SEPA and if satisfactory will be directly referenced within the permit thereby becoming an extension of the permit condition. This means that the operator must comply with the monitoring plan and changes to the plan must be done through the formal permit variation process.

5.1.3 SEPA must be notified no fewer than 14 days before monitoring is undertaken.

Operators are required to notify SEPA when monitoring will take place so that the process can be monitored and audited by SEPA to ensure that samples are being collected in accordance with the monitoring plan and that compliance with environmental standards is being properly assessed.

SCHEDULE 6: ENVIRONMENTAL EVENTS

 

6.1 Notification of SEPA

6.1.1 SEPA must be notified via its pollution hotline contact telephone number as soon as reasonably practicable, and in any case within 24 hours of identification of the event, of the following:

  • (a) any event which has caused or could cause adverse impact to the water environment or harm to human health;
  • (b) any event that results or could result in an emission to the water environment that is not authorised by this permit;
  • (c) a breach of any condition of this permit.

SEPA sets conditions in the permit to protect the water environment however accidents or incidents may occur which are
unforeseen. This condition requires operators to notify SEPA should such an incident occur as listed above. We would expect the operator to contact us as soon as they are aware of an event unless there was mitigating circumstances (such as power failure) where this would be unreasonable

 

6.2 Management of the Event

6.2.1 All measures that are reasonably practicable must be taken to stop an event, as described in 6.1.1, and to minimise and/or mitigate its effect on the environment.

The Authorised Person must ensure that any event at an authorised site is appropriately managed and that any impact on the environment is properly addressed.

6.3 Report of the Event

6.3.1 Within 14 days of an event as described in 6.1.1, a report must be submitted to SEPA detailing:

  • (a) the reason(s) for the event;
  • (b) the action(s) taken to stop the event and minimise and/or mitigate its impacts;
  • (c) the action(s) taken to prevent the event from recurring.

It is important to understand the cause or causes of an incident or event, and the steps taken to deal with it, to ensure that procedures can be put in place to prevent it from happening again. SEPA needs to understand the underlying reasons behind any incident or event so that the environmental impact can be adequately assessed and remediated.  We may also use this information to help inform future decision making.

SCHEDULE 7: RECORD KEEPING AND DATA SUBMISSION

 

7.1 Data Recording

7.1.1 All information recorded, kept, or submitted to SEPA in accordance with a condition of this Permit must be true and accurate.

It is important that all information gathered in relation to the authorised activity is accurate so that compliance with the permit can be assessed correctly.

7.1.2 Records must be kept of the following:

  • (a) all medicine use notifications;
  • (b) start and finish dates of each sea lice medicine treatment;
  • (c) quantities of medicine used during each sea lice medicine treatment;
  • (d) weight of [species] at end of each sea lice medicine treatment (tonnes);
  • (e) veterinary prescription for each sea lice medicine treatment;
  • (f) veterinary authorisations in accordance with Condition 3.5.3;
  • (g) total weight of [species] harvested per month.

7.1.3 Records must be kept for a minimum of 6 years and must be provided to SEPA upon request.

The site operator must hold this information so that SEPA Officers can carry out audits of the operation of the fish farm. We may also request this information at any time. Records must be kept for a minimum time period so that SEPA can, for example, track stocking information or medicine use over time.

7.2 Data Reporting

7.2.1 The information specified in Table 5 must be submitted on a quarterly basis no later than the relevant submission deadline in Table 6 of every calendar year during which the site is operational.

Table 5:  Data Reporting Requirements
Requirement number Information to be Submitted
1 Maximum weight of [Atlantic Salmon OR Rainbow Trout] held on site during each month (tonnes)
2 Total amount of feed used per month (tonnes)
3 Total Salmosan and/or Salmosan Vet and/or Azasure use each month (g)
4 Total AMX and/or ALPHAMAX use each month (litres)
5 Total Slice and/or Quinafish use each month (g)
6 Total azamethiphos use each month (g)
7 Total deltamethrin use each month (g)
8 Total emamectin benzoate use each month (g)
9 Total use of each anti-parasiticide listed in the PSL or PSWP each month (g)
10 Total use of each anti-microbial listed in the PSL or PSWP each month (g
11

Total weight of mortalities of [Atlantic Salmon OR Rainbow Trout] each month (kg)

 

Table 6 Data Reporting Submission Deadline
Quarter Reporting period Submission deadline
1 1 January - 31 March 28 April
2 1 April - 30 June 28 July
3 1 July - 30 September 28 October
4 1 October - 31 December 28 January

Operators must submit information to SEPA every 3 months in order to show that they have adhered with the conditions of their permit.  SEPA assesses this information in inspections and uses it to analyse trends across the sector.  The information is also published by SEPA and partner agencies.

7.2.2 Results from the analysis of all samples collected in accordance with the SWMP [REF] must be submitted to SEPA no later than [XX] weeks from the final date of each survey period.

Operators must collect and analyse environmental samples in order to demonstrate that they have complied with environmental standards. SEPA recognises that the collection and analysis of environmental samples is a time consuming process and will impose reasonable timescales for the submission of this information.

7.2.3 Within [X] weeks of the end of each growth cycle a description of each of the steps taken in accordance with 3.1.1 and the dates and/or time period(s) over which they were implemented must be submitted to SEPA.

Operators must demonstrate to SEPA that they have taken reasonable steps to minimise the use of medicines on their site.  SEPA will publish this information.Operators must demonstrate to SEPA that they have taken reasonable steps to minimise the use of medicines on their site. SEPA will use this information to assess against condition 3.1.1. It will also be used to determine trends at the site and across the sector. This will enable us to build a wider picture of medicine use across industry and what are appropriate and effective ways to minimising the use of medicines. SEPA will publish this information.

7.2.4 The information must be submitted via email, in the Excel Spreadsheet supplied by SEPA, to ffbiomass@sepa.org.uk.

The information provided to SEPA must be legible, provided in an accessible format and sent to a specified address so that it can be collated and tracked.