Environmental Performance Assessment Scheme (EPAS) - a fair way to report performance​ 

Closes 30 Jun 2025

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Section 10: Priority site status and compliance recovery plans

We plan to identify sites where the relevant operator remains ‘Unacceptable’ for more than 90 days as a ‘Priority site’. This is to reflect the ongoing impact to the environment and communities, and to act as a driver for the operator to improve their environmental performance. 

A priority site designation is important – our intention is to publish proactively and raise awareness of the operators of these sites. 

Once an operator has been rated as ‘Unacceptable’ in relation to a specific site, they will have a maximum of 90 days to prepare a compliance recovery plan and have this confirmed by us as containing reasonable steps to resolve any non-compliance in a timely manner. If that is achieved, the relevant site will not be added to the priority site list. However, if the non-compliance is continuing to cause more substantial environmental harm such as a Category 1 or 2 environmental event, the site will remain on the priority site list, even if the relevant operator has a compliance recovery plan in place. 

If an operator rated as ‘Unacceptable’ in relation to a specific site fails to deliver against a compliance recovery plan without prior agreement from us, they will be published on the priority sites list. 

Priority sites are sites that are 'Unacceptable' for more than 90 days with no compliance recovery plan in place

SEPA will actively raise awareness of priority sites on an ongoing basis

A timeline showing how compliance category, environmental performance rating, having an agreed compliance recovery plan and being designated as a priority site interact.

Figure 15: If an operator's site is rated as ‘Unacceptable’, it will be listed as a priority site, if no compliance recovery plan is agreed within 90 days. Once an agreed compliance recovery plan is in place, it will be removed from the priority site list.

A timeline showing how compliance category, environmental performance rating, having an agreed compliance recovery plan and being designated as a priority site interact.

Figure 16: If an operators’ site is rated as ‘Unacceptable’ and a compliance recovery plan is agreed within 90 days, it will not be listed as a priority site.

Question 14: How far do you agree or disagree that publishing a priority sites list would drive improvements in performance?

More information

Our priorities are:  

  • 'Unacceptable' sites with no compliance recovery plan in place and   

  • Sites causing ongoing harm (Category 1 or 2 event), despite having a compliance recovery plan in place.   

We propose to publish a list of priority sites on an ongoing basis.   

Question 15: How long should an operator have to establish a compliance recovery plan before a site rated as 'Unacceptable' is listed as a 'priority site'?

More information

Our proposals for priority site status and compliance recovery plans are set out in section 10. We propose to give operators rated as ‘Unacceptable’ 90 days to establish a compliance recovery plan that we have confirmed contains reasonable steps to resolve compliance issues before being designated as a ‘Priority site’, see figure 15 section 10. We recognise that we will need to provide guidance on what constitutes an appropriate compliance recovery plan, and that some issues can be so complex a multi-phase plan will be required; we will do this before the scheme launches.