Response 968200301

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About You

Are you responding as an individual or an organisation?

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Individual
Ticked Organisation

What is your organisation?

Organisation
Scottish Salmon Producers' Organisation (SSPO)

Part 2: Policy Overview

1. Do you agree with the benefits set out here?

Please select one item
Ticked Yes
No

2. Are there any other comments you would like to make on Part 2?

Are there any other comments you would like to make on Part 2?§
This process of integrating multiple permitting schemes is inherently complex and bureaucratic. It is unlikely that this particular change will result in improvements to how the finfish aquaculture sector is regulated, however over time simplified regulation may evolve. The aims of this better environmental regulation are good and we await to see the outcomes

3. How could SEPA better support the uptake of new technologies?

How could SEPA better support the uptake of new technologies?
By being open to trials of new technology on a small or limited scale on the understanding that work is required to develop understanding and future benefits to the wider environment. SEPA should be willing to try and develop innovation to allow future benefits for industry and the environment.

Part 3: Key features of the new framework for authorisation holders.

4. Do you agree that the framework should include a set of universal outcomes?

Please select one item
Ticked Yes
No

5. If so, are the outcomes proposed the right ones?

Please select one item
Ticked Yes
No
Comments:
Generally, yes but this depends on the precise definition of environmental harm

6. Do you see any opportunities within your sector for industry- led guidance to be produced to support this approach and how could it support you to deliver better?

Please select one item
Ticked Yes
No
Comments:
As a sector we have a history of developing codes of practice so there is potential within the aquaculture sector, however it would depend on the specific content.

7. Do you understand the descriptions of the regulated activities in Annex 2?

Please select one item
Ticked Yes
No

8. Do you agree that these are the right factors for SEPA to consider?

Please select one item
Ticked Yes
No

9. Do you agree that SEPA should consult on the guidance setting out the likely tier of authorisation for particular activities?

Please select one item
Ticked Yes
No

20. Do you agree with the proposal to have a statutory determination period of four months for the majority of permit applications?

Please select one item
Ticked Yes
No

23. Do you agree with the proposals for variations?

Please select one item
Ticked Yes
No
If not, why not?
It is not clear in 3.6.14 whether administrative changes are included as a variation. This should differentiate between administrative and ‘significant variations’.

25. Do you agree with the proposals for surrender?

Please select one item
Ticked Yes
No
If not, why not?
The challenge for surrendering marine aquaculture permits has been identifying the current holders of the permits. The approach proposed does not address the situation where the holder of the permit cannot be contacted.

27. Do you agree a notice used in the way set out in 3.7.10 to 3.7.12 is a different type of notice and should be therefore be called something different, such as an improvement notice?

Please select one item
Ticked Yes
No

29. Do you agree we should retain suspension notices for use in circumstances where we wish to suspend an activity in order to protect the environment, but the authorised person is not being ‘enforced’ against?

Please select one item
Ticked Yes
No

30. Do you agree SEPA should have the power to revoke authorisations in these circumstances?

Please select one item
Ticked Yes
No

31. Do you agree that appeals against SEPA decisions should continue to be heard by the DPEA on behalf of Scottish Ministers?

Please select one item
Ticked Yes
No
If not, which alternative body do you think should hear such appeals and why?
Yes, however the appeals process through the Scottish Land Court is a very expensive process and will deter appeals based on significant financial risk.

Part 4: Key features of the new framework for the public

34. Do you support SEPA having more flexibility in how information is made available to the public?

Please select one item
Ticked Yes
No

35. Do you agree that a consistent, flexible and proportionate approach to public participation should be adopted?

Please select one item
Ticked Yes
No

36. Do you agree that the procedural arrangements for third party call-in under CAR should be extended to all regulated activities?

Please select one item
Ticked Yes
No