Local governments face a unique issue when managing contaminated land to the requirements of current regulation. We are more likely to manage multiple sites, those sites are more likely to be accessible to the public and they often have a legacy of complicated responsibilities. Current regulations require the use of external contaminated land consultants and auditors, and presumes a site by site response. Without our input, the result can be inefficient processes being imposed on councils, and in some cases the assignment of responsibilities that cannot be discharged.
This talk covers the findings from a review of contaminated land Environmental Management Plans (EMP) for City of Sydney assets. These EMPs were developed by various specialist consultants over time, often written in isolation from operational teams and corporate governance systems. The review identified a range of issues that made compliance with these documents difficult or impossible. These issues also meant the City could not fully discharge its Duty of Care for people who need to work on or manage the land.
Solutions to these issues include the development of a guidance document and an online register.
The guidance specifies requirements for Environmental Management Plans covering City owned and managed land. It sets out how to write and structure the EMP to ensure people who may need to undertake activities on the land can easily use the document.
The online register tracks contamination decisions through the project and planning stages, and then into ongoing management. It is part of our corporate risk and governance system, improving transparency, efficiency and compliance tracking.