Annual compliance report 2023

The EPA has reviewed Snowy Hydro Limited’s annual compliance report for the 2023 cloud seeding season and has found that:

the compliance report was submitted to the relevant Ministers and the EPA by the due date
Snowy Hydro Limited has complied with all of its obligations as detailed in the Act
Snowy Hydro Limited complied with all its obligations in the Environment Management Plan.

Snowy Hydro Limited has been conducting a winter cloud seeding trial in the NSW Snowy Mountains area since 2004. On 31 May 2013 amendments to the Snowy Mountains Cloud Seeding Act 2004 (the Act) came into effect enabling Snowy Hydro Limited to conduct permanent cloud seeding operations within an expanded area of the Snowy Mountains, in accordance with an Environmental Management Plan approved by relevant Ministers. The Act defines the relevant Ministers as the Minister for the Environment and the Minister for Planning and Environment, who approved the Environmental Management Plan on 28 June 2018. In accordance with the Act, the Environmental Management Plan must be reviewed at least once every 5 years. The EPA coordinated the 5-yearly review in 2023 in consultation with relevant stakeholders. The revised Environmental Management Plan was approved by the relevant ministers in July 2023

The Act also authorises aerial application of existing and alternative cloud seeding chemicals and prescribed a review and oversight role for the NSW Environment Protection Authority (EPA).

Snowy Hydro Limited is required to provide a report to the EPA detailing its compliance with the Environmental Management Plan and the results of any research and monitoring into the impact of cloud seeding operations on the environment by 31 March each year. The EPA is required to review this report and convey its findings, along with any recommendations, to the Board of the Environment Protection Authority and the relevant Ministers.

Conclusions and recommendations

After reviewing the Snowy Hydro Limited 2023 Annual Compliance Report and Snowy Hydro Limited on-ground operations, the EPA concludes that:

Snowy Hydro Limited has complied with all obligations as detailed in the Act.

Snowy Hydro Limited has complied with all obligations as detailed in the Environmental Management Plan for cloud seeding operations approved by the relevant Ministers in July 2023.

Snowy Hydro Limited has complied with all obligations as detailed in the Protection of the Environment Operations Act 1997.

Analysis of sampling across all matrices carried out during the 2023 cloud seeding season showed silver concentrations remain several orders of magnitude below relevant guideline values.

It is recommended that:

Monitoring should be continued as per the schedule of the EMP, and data compared over time to identify trends.

Future reviews are also undertaken in consultation with input from partner agencies of the NPWS and DCCEEW.

Snowy Hydro Limited continues to pursue research opportunities on the cloud seeding operations in the Snowy Mountains.

The outcomes of this review are communicated to the relevant Ministers.

Obligations under the Snowy Mountains Cloud Seeding Act 2004	Compliance status (report reference)
The area to be primarily targeted for the increased precipitation is land within the Snowy water catchment.	(1.4) Addressed
Operations may be carried out only if there is an approved Environmental Management Plan.	(1.1) Addressed
Operations must be carried out in accordance with the approved Environmental Management Plan (whether being carried out within or outside the Snowy water catchment).	(1) Addressed All operations carried out within the catchment.
The seeding agent used must be an approved seeding agent and used in accordance with the conditions (if any) of its approval as a seeding agent.	(2.2) Addressed
The tracing agent used must be an approved tracing agent and used in accordance with the conditions (if any) of its approval as a tracing agent.	(2.2) Addressed Tracing agent not used.
The seeding agent and tracing agent must be discharged by the use of an approved method.	(2.2) Approved Land-based aerosol generators.
The discharge must be carried out in accordance with the conditions (if any) of its approval as a method of discharge.	(2) Addressed
The discharge of the seeding agent is to be carried out at a time when increased precipitation in the Snowy water catchment is likely to fall as snow at an elevation above 1400 metres from the mean sea level.	(3.1) Addressed
Snowy Hydro Limited must consult with the NPWS before carrying out any new operations involving a land- based method of discharge of seeding or tracing agent within any area of land reserved under the National Parks and Wildlife Act 1974 (that is, operations in an area that has not been the subject of previous consultation with the NPWS).	(2.3) Addressed No new operations carried out.
Snowy Hydro Limited must consult with the NPWS before installing, or carrying out major modifications to, any facilities required to carry out cloud seeding operations within any area of land reserved under the National Parks and Wildlife Act 1974.	(2.3) Addressed No major modifications or new installations carried out.
Installation of new facilities for cloud seeding operations must not be carried out within any wilderness area (within the meaning of the National Parks and Wildlife Act 1974).	(2.3) Addressed No new facilities installed.
A seeding agent is not to be discharged from land-based aerosol generators in any wilderness area (within the meaning of the National Parks and Wildlife Act 1974).	(1.4) Addressed All land-based generators located in approved areas by NPWS.
An application for approval of the use of a thing as a seeding agent in cloud seeding operations must be accompanied by details of the health risk assessment carried out in relation to the proposed use of the seeding agent (including the process used to carry out the assessment and the results of the assessment).	(N/A)
An application for approval of the use of a thing as a tracing agent in cloud seeding operations must be accompanied by details of the health risk assessment carried out in relation to the proposed use of the tracing agent (including the process used to carry out the assessment and the results of the assessment).	(N/A)
An application for approval of an Environmental Management Plan must be accompanied by an independent scientific assessment of any proposed cloud seeding operations that differ from the operations currently authorised. Any such scientific assessment must comply with any requirements imposed by the relevant Ministers and notified to Snowy Hydro Limited.	(N/A)
Snowy Hydro Limited must, by 31 March in each year or such later date as agreed by the relevant Ministers, provide a report on its cloud seeding operations during the period of 12 months ending on 31 December in the previous year to the relevant Ministers and to the EPA. Without limiting the generality of subsection (1), the report must contain the following information: details of compliance with the approved Environmental Management Plan details of research concerning, and monitoring of, the impact of tracing agents and seeding agents on the environment (including the findings of any such research or monitoring).	(4) Addressed Report on cloud seeding operations received by EPA 28 March 2024.

Obligations under the Snowy Mountains Cloud Seeding Act 2004

Compliance status (report reference)

The area to be primarily targeted for the increased precipitation is land within the Snowy water catchment.

(1.4) Addressed

Operations may be carried out only if there is an approved Environmental Management Plan.

(1.1) Addressed

Operations must be carried out in accordance with the approved Environmental Management Plan (whether being carried out within or outside the Snowy water catchment).

(1) Addressed

All operations carried out within the catchment.

The seeding agent used must be an approved seeding agent and used in accordance with the conditions (if any) of its approval as a seeding agent.

(2.2) Addressed

The tracing agent used must be an approved tracing agent and used in accordance with the conditions (if any) of its approval as a tracing agent.

(2.2) Addressed Tracing agent not used.

The seeding agent and tracing agent must be discharged by the use of an approved method.

(2.2) Approved

Land-based aerosol generators.

The discharge must be carried out in accordance with the conditions (if any) of its approval as a method of discharge.

(2) Addressed

The discharge of the seeding agent is to be carried out at a time when increased precipitation in the Snowy water catchment is likely to fall as snow at an elevation above 1400 metres from the mean sea level.

(3.1) Addressed

Snowy Hydro Limited must consult with the NPWS before carrying out any new operations involving a land- based method of discharge of seeding or tracing agent within any area of land reserved under the National

Parks and Wildlife Act 1974 (that is, operations in an area that has not been the subject of previous consultation with the NPWS).

(2.3) Addressed

No new operations carried out.

Snowy Hydro Limited must consult with the NPWS before installing, or carrying out major modifications to, any facilities required to carry out cloud seeding operations within any area of land reserved under the National Parks and Wildlife Act 1974.

(2.3) Addressed

No major modifications or new installations carried out.

Installation of new facilities for cloud seeding operations must not be carried out within any wilderness area (within the meaning of the National Parks and Wildlife Act 1974).

(2.3) Addressed

No new facilities installed.

A seeding agent is not to be discharged from land-based aerosol generators in any wilderness area (within the meaning of the National Parks and Wildlife Act 1974).

(1.4) Addressed

All land-based generators located in approved areas by NPWS.

An application for approval of the use of a thing as a seeding agent in cloud seeding operations must be accompanied by details of the health risk assessment carried out in relation to the proposed use of the seeding agent (including the process used to carry out the assessment and the results of the assessment).

(N/A)

An application for approval of the use of a thing as a tracing agent in cloud seeding operations must be accompanied by details of the health risk assessment carried out in relation to the proposed use of the tracing agent (including the process used to carry out the assessment and the results of the assessment).

(N/A)

An application for approval of an Environmental Management Plan must be accompanied by an independent scientific assessment of any proposed cloud seeding operations that differ from the operations currently authorised. Any such scientific assessment must comply with any requirements imposed by the relevant Ministers and notified to Snowy Hydro Limited.

(N/A)

Snowy Hydro Limited must, by 31 March in each year or such later date as agreed by the relevant Ministers, provide a report on its cloud seeding operations during the period of 12 months ending on 31 December in the previous year to the relevant Ministers and to the EPA. Without limiting the generality of subsection (1), the report must contain the following information:

details of compliance with the approved Environmental Management Plan
details of research concerning, and monitoring of, the impact of tracing agents and seeding agents on the environment (including the findings of any such research or monitoring).

(4) Addressed

Report on cloud seeding operations received by EPA 28 March 2024.

Obligations under the Environmental Management Plan	Compliance status (report reference
Cloud seeding will not commence if the freezing level over the catchment is greater than 1600 metres, and will be suspended or terminated if the freezing level rises above 1600 metres during cloud seeding campaigns.	(3.1) Addressed There were no instances where the freezing level rose above 1600 m, therefore additional controls were not triggered.
Additional controls will be implemented when the freezing level is between 1550 metres and 1600 metres above sea level, including: video monitoring at locations over the target area at approximately 1400 metre elevation to assist in determining that precipitation is not falling as rain when required, undertaking telephone polling to external parties and/or Snowy Hydro Limited personnel within the target area to confirm that precipitation is not falling as rain at approximately 1400 metre elevation.	(3.1)Addressed There were no instances where the freezing level was between 1150 -1600 m.
Snowy Hydro Limited will consult with the NPWS prior to undertaking major vegetation management and site access beyond maintenance of the existing tracks and site footprints.	(2.3) N/A
The Annual Compliance Report will include: sample locations, data results, evaluation and adaptive management recommendations for the environmental monitoring program details (including results and evaluation) of any emerging environmental issues results from meteorological monitoring that can demonstrate Snowy Hydro Limited’s compliance with the requirement to ensure that increased precipitation falls as snow in areas at an elevation above 1400 metres above sea level results from analyses of downwind precipitation the event time and duration over which cloud seeding occurred any accidents or break downs resulting in spillage of cloud seeding agents, fuel, or failure of controls specified in this Environmental Management Plan the quantity of cloud seeding agents that were released per seeding event per generator	(a – 4.1-4.3) Addressed (b – 4.4) Addressed: No emerging environmental issues (c – 3.1) Addressed: Table 3.1. (d – 3.2) Addressed: Figure 3.1 (e – 2.1) Addressed: Table 2.1 (f – 2.3) Addressed: No accidents or breakdowns (g – 2.2) Addressed: Table 2.2
In addition to the Annual Compliance Report, Snowy Hydro Limited will also prepare a Cloud Seeding Operations Annual Report which is to be made publicly available on the Snowy Hydro Limited website within a reasonable timeframe after any recommendations from the Board of the EPA and the relevant Ministers. The Cloud Seeding Operations Annual Report will include, but not be limited to: summary statistics of the Environmental Monitoring Program details of compliance with approved Environmental Management Plan summary statistics on the overall duration over which cloud seeding occurred and the total amount of cloud seeding agents that were released over the season.	(1.2) N/A
Disputes between NSW government agencies and Snowy Hydro Limited with regards to cloud seeding operations will be resolved in accordance with the following escalation process: use of established paths of communication between Snowy Hydro Limited and the agency (officer to officer) communication between Snowy Hydro Limited Executive Officer and agency Department Director communication between the Chief Executives of Snowy Hydro Limited and the agency.	(2.4) Addressed No disputes between NSW Government agencies and Snowy Hydro Limited.
Snowy Hydro Limited will continue to consult with other relevant land managers with respect to vegetation management and site access. Snowy Hydro Limited will also consult with relevant land managers in situations where major visual modifications are made to infrastructure or if new sites are installed and/or existing sites are removed. No new infrastructure will be established without the prior endorsement by the relevant land manager.	(2.3) Addressed No new infrastructure established, no major visual modifications made to existing infrastructure, and no infrastructure decommissioned.
DCCEEW, the EPA and other identified stakeholders will be advised as soon as practicable following the commencement of, and on the conclusion of cloud seeding campaigns.	(2.1) Addressed DCCEEW and EPA and other identified stakeholders were advised by email.
Existing sites authorised under the Act will be defined by Snowy Hydro Limited (coordinates and identified on a map), and provided to DCCEEW and the EPA prior to commencement of first annual winter operations. Thereafter, prior to the installation of any new authorised sites, updated coordinates and maps are to be provided to DCCEEW and the EPA.	(1.4) Addressed A map of existing sites and details of their coordinates were provided to the EPA and DCCEEW in June 2013. There were no changes to infrastructure in 2023.
Implement all Management Controls (Table 1), being those included for each of the following activities: installation and modification of generators operation and maintenance of generators (including release of cloud seeding agents and increased precipitation) storage and preparation of cloud seeding agents and other chemicals installation and modification of weather stations installation and modification of communications equipment operation and maintenance of weather stations and communications infrastructure operation and maintenance of snow sampling sites Environmental Monitoring Program removal of infrastructure and rehabilitation of sites.	(2.3) Addressed Infrastructure, including cloud seeding agents and fuel, are managed in accordance with these requirements.
Meteorological monitoring
Undertake monitoring of downwind precipitation - mean wintertime daily precipitation anomalies will be updated each year and included in the Annual Compliance Report following cloud seeding operations to continue to monitor downwind precipitation.	(3.2) Addressed Figure 3.1
Snow sampling profile sites and preferred access routes will be defined by Snowy Hydro Limited (coordinates and identified on a map) and provided to DCCEEW and EPA prior to commencement of first annual winter snow sampling operations. Updated coordinates and maps are to be provided to DCCEEW and EPA if sites change.	(1.4) Addressed No snow profile sampling took place in 2023.
Environmental chemistry monitoring
Environmental sampling to be undertaken as per Table 3 in the Environmental Management Plan.	(4.1.2) Addressed Table 4.1.
Specific quality controls applied to the collection and handling of all samples collected for the cloud seeding program include: the use of a new clean plastic vial/bag for each sample the use of a new pair of clean disposable gloves at each site and procedures to minimise contact with the inside of vials/bags to minimise the potential for sample contamination all sampling equipment is washed with ultra-pure water or water from the sampling location prior to use the use of a data management system including the barcoding of each sample to ensure every sample is individually trackable from collection, return to base, dispatch to the laboratory and the return of results.	(4.1.3) Addressed Samples are collected and processed in accordance with internal work instructions and quality assurance and quality control procedures.
Samples sent for laboratory analyses will be analysed for total silver concentration with an appropriate level of quality assurance and quality control (QA/QC).	(4.1.3) Addressed
For those samples that are analysed chemically, the data is to be analysed	(4.1.5) Addressed
statistically and interpreted on the basis of three statistical tools.	Due to extremely low values observed in 2023 and previous surveys, no statistical analysis were undertaken for this matrix.
Implementation of steps in decision tools and environmental suspension criteria.	(4.1.1, 4.1.5) Addressed
Macroinvertebrates monitoring
Sampling will be undertaken on a five- year sampling interval, with the first round of sampling to be undertaken following the first year of cloud seeding operations. In the event that additional river sediment sampling is required as a result of the triggers outlined in the Environmental Management Plan, macroinvertebrates sampling will also be undertaken at the affected locations.	(4.2) Addressed Macroinvertebrate sampling was required in 2023.
If macroinvertebrate sampling sites are changed and/or added outside of the Environmental Management Plan Review process, updates to the Environmental Management Plan will be provided to EPA/DCCEEW prior to sampling being undertaken.	(4.2) Addressed No changes made during the 2023 sampling.
The macroinvertebrate sampling program implemented by Snowy Hydro Limited (and endorsed by DCCEEW) uses the NSW Australian River Assessment System (AUSRIVAS) protocol.	(4.2) Addressed Macroinvertebrate sampling was conducted using the AUSRIVAS protocol during the 2023 season.
Additional monitoring
Relevant agencies of the Minister for the Environment may request consideration by Snowy Hydro Limited of emerging environmental issues between reviews of this Environmental Management Plan. In order for issues to be considered by Snowy Hydro Limited, the agency will provide a clear outline of the issue to Snowy Hydro Limited based on direct evidence or established scientific theory. The agency and Snowy Hydro Limited will then agree on an appropriate research/monitoring/consultation/reporting regime.	(4.4) N/A No emerging environmental issues were raised with, or identified by, Snowy Hydro Limited during this reporting period.

Obligations under the Environmental Management Plan

Compliance status (report reference

Cloud seeding will not commence if the freezing level over the catchment is greater than 1600 metres, and will be suspended or terminated if the freezing level rises above 1600 metres during cloud seeding campaigns.

(3.1) Addressed

There were no instances where the freezing level rose above 1600 m, therefore additional controls were not triggered.

Additional controls will be implemented when the freezing level is between 1550 metres and 1600 metres above sea level, including:

video monitoring at locations over the target area at approximately 1400 metre elevation to assist in determining that precipitation is not falling as rain
when required, undertaking telephone polling to external parties and/or Snowy Hydro Limited personnel within the target area to confirm that precipitation is not falling as rain at approximately 1400 metre elevation.

(3.1)Addressed

There were no instances where the freezing level was between 1150 -1600 m.

Snowy Hydro Limited will consult with the NPWS prior to undertaking major vegetation management and site access beyond maintenance of the existing tracks and site footprints.

(2.3) N/A

The Annual Compliance Report will include:

sample locations, data results, evaluation and adaptive management recommendations for the environmental monitoring program
details (including results and evaluation) of any emerging environmental issues
results from meteorological monitoring that can demonstrate Snowy Hydro Limited’s compliance with the requirement to ensure that increased precipitation falls as snow in areas at an elevation above 1400 metres above sea level
results from analyses of downwind precipitation
the event time and duration over which cloud seeding occurred
any accidents or break downs resulting in spillage of cloud seeding agents, fuel, or failure of controls specified in this Environmental Management Plan
the quantity of cloud seeding agents that were released per seeding event per generator

(a – 4.1-4.3) Addressed

(b – 4.4) Addressed: No emerging environmental issues

(c – 3.1) Addressed: Table 3.1.

(d – 3.2) Addressed: Figure 3.1

(e – 2.1) Addressed: Table 2.1

(f – 2.3) Addressed: No accidents or breakdowns (g – 2.2)

Addressed: Table 2.2

In addition to the Annual Compliance Report, Snowy Hydro Limited will also prepare a Cloud Seeding Operations Annual Report which is to be made publicly available on the Snowy Hydro Limited website within a reasonable timeframe after any recommendations from the Board of the EPA and the relevant Ministers. The Cloud Seeding Operations Annual Report will include, but not be limited to:

summary statistics of the Environmental Monitoring Program
details of compliance with approved Environmental Management Plan
summary statistics on the overall duration over which cloud seeding occurred and the total amount of cloud seeding agents that were released over the season.

(1.2) N/A

Disputes between NSW government agencies and Snowy Hydro Limited with regards to cloud seeding operations will be resolved in accordance with the following escalation process:

use of established paths of communication between Snowy Hydro Limited and the agency (officer to officer)
communication between Snowy Hydro Limited Executive Officer and agency Department Director
communication between the Chief Executives of Snowy Hydro Limited and the agency.

(2.4) Addressed

No disputes between NSW Government agencies and Snowy Hydro Limited.

Snowy Hydro Limited will continue to consult with other relevant land managers with respect to vegetation management and site access. Snowy Hydro Limited will also consult with relevant land managers in situations where major visual modifications are made to infrastructure or if new sites are installed and/or existing sites are removed. No new infrastructure will be established without the prior endorsement by the relevant land manager.

(2.3) Addressed

No new infrastructure established, no major visual modifications made to existing infrastructure, and no infrastructure decommissioned.

DCCEEW, the EPA and other identified stakeholders will be advised as soon as practicable following the commencement of, and on the conclusion of cloud seeding campaigns.

(2.1) Addressed

DCCEEW and EPA and other identified stakeholders were advised by email.

Existing sites authorised under the Act will be defined by Snowy Hydro Limited (coordinates and identified on a map), and provided to DCCEEW and the EPA prior to commencement of first annual winter operations. Thereafter, prior to the installation of any new authorised sites, updated coordinates and maps are to be provided to DCCEEW and the EPA.

(1.4) Addressed

A map of existing sites and details of their coordinates were provided to the EPA and DCCEEW in June 2013. There were no changes to infrastructure in 2023.

Implement all Management Controls (Table 1), being those included for each of the following activities:

installation and modification of generators
operation and maintenance of generators (including release of cloud seeding agents and increased precipitation)
storage and preparation of cloud seeding agents and other chemicals
installation and modification of weather stations
installation and modification of communications equipment
operation and maintenance of weather stations and communications infrastructure
operation and maintenance of snow sampling sites
Environmental Monitoring Program
removal of infrastructure and rehabilitation of sites.

(2.3) Addressed

Infrastructure, including cloud seeding agents and fuel, are managed in accordance with these requirements.

Meteorological monitoring

Undertake monitoring of downwind precipitation - mean wintertime daily precipitation anomalies will be updated each year and included in the Annual Compliance Report following cloud seeding operations to continue to monitor downwind precipitation.

(3.2) Addressed

Figure 3.1

Snow sampling profile sites and preferred access routes will be defined by Snowy Hydro Limited (coordinates and identified on a map) and provided to DCCEEW and EPA prior to commencement of first annual winter snow sampling operations.

Updated coordinates and maps are to be provided to DCCEEW and EPA if sites change.

(1.4) Addressed

No snow profile sampling took place in 2023.

Environmental chemistry monitoring

Environmental sampling to be undertaken as per Table 3 in the Environmental Management Plan.

(4.1.2) Addressed

Table 4.1.

Specific quality controls applied to the collection and handling of all samples collected for the cloud seeding program include:

the use of a new clean plastic vial/bag for each sample
the use of a new pair of clean disposable gloves at each site and procedures to minimise contact with the inside of vials/bags to minimise the potential for sample contamination
all sampling equipment is washed with ultra-pure water or water from the sampling location prior to use
the use of a data management system including the barcoding of each sample to ensure every sample is individually trackable from collection, return to base, dispatch to the laboratory and the return of results.

(4.1.3) Addressed

Samples are collected and processed in accordance with internal work instructions and quality assurance and quality control procedures.

Samples sent for laboratory analyses will be analysed for total silver concentration with an appropriate level of quality assurance and quality control (QA/QC).

(4.1.3) Addressed

For those samples that are analysed chemically, the data is to be analysed

(4.1.5) Addressed

statistically and interpreted on the basis of three statistical tools.

Due to extremely low values observed in 2023 and previous surveys, no statistical analysis were undertaken for this matrix.

Implementation of steps in decision tools and environmental suspension criteria.

(4.1.1, 4.1.5) Addressed

Macroinvertebrates monitoring

Sampling will be undertaken on a five- year sampling interval, with the first round of sampling to be undertaken following the first year of cloud seeding operations. In the event that additional river sediment sampling is required as a result of the triggers outlined in the Environmental Management Plan, macroinvertebrates sampling will also be undertaken at the affected locations.

(4.2) Addressed Macroinvertebrate sampling was required in 2023.

If macroinvertebrate sampling sites are changed and/or added outside of the Environmental Management Plan Review process, updates to the Environmental Management Plan will be provided to EPA/DCCEEW prior to sampling being undertaken.

(4.2) Addressed

No changes made during the 2023 sampling.

The macroinvertebrate sampling program implemented by Snowy Hydro Limited (and endorsed by DCCEEW) uses the NSW Australian River Assessment System (AUSRIVAS) protocol.

(4.2) Addressed

Macroinvertebrate sampling was conducted using the AUSRIVAS protocol during the 2023 season.

Additional monitoring

Relevant agencies of the Minister for the Environment may request consideration by Snowy Hydro Limited of emerging environmental issues between reviews of this Environmental Management Plan.

In order for issues to be considered by

Snowy Hydro Limited, the agency will provide a clear outline of the issue to Snowy Hydro Limited based on direct evidence or established scientific theory. The agency and Snowy Hydro Limited will then agree on an appropriate research/monitoring/consultation/reporting regime.

(4.4) N/A

No emerging environmental issues were raised with, or identified by, Snowy Hydro Limited during this reporting period.

Annual Compliance Report 2023: Snowy Hydro Limited Cloud Seeding Program

About cloud seeding expand

Review and findings

Findings

Discussion

Conclusions and recommendations

Compliance with the act

Compliance with the EMP