SuRF UK: Sustainable decision-making
for remediation in the UK
Brian Bone, Bone Environmental Consultant Ltd.
Sustainable Remediation Forum-UK
Steering Group Member
[email protected]
Clean Soil Network , Göteborg, 28-29 March 2012
This presentation
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Drivers for sustainable remediation in UK
Where we have come from
Where we are now – SuRF-UK
Links with developing policy and
guidance?
• Challenges and opportunities
• Summary
Sustainable Development
• Sustainable development
• ‘Development that meets the needs
Positive
of the present without
benefits
compromising the ability of future
+
generations to meet their own
needs’ (Report of the World
Commission on Environment and
Development 1987, the Brundtland
report)
Negative
• Sustainable remediation
• Application of the principles of
sustainable development to
remediation
impacts
_
.. a net benefit
Regulatory Drivers
• European Directives
• Waste Framework Directive
• Hierarchy to promote sustainable waste
management
• Escalating taxation on disposal
• Water Framework Directive
• Preferred solution (to achieve good status) … best
balance of social, economic and environmental
costs
• Draft Soil Protection Framework
• Deciding on remediation actions, Member States to
consider … social, economic and environmental
impacts, cost-effectiveness and technical feasibility
of the actions envisaged
Regulatory Drivers
• UK legislation
• Planning regime (revision imminent)
• Underpins sustainable development
• Draft national Planning Policy Framework
• Environment Act 1995 requires environment
agencies
• To contribute to the goal of achieving sustainable
development/have regard to social and economic needs
• To take account of likely costs and benefits in
considering how or whether to exercise statutory
powers
• Contaminated land regime (revision imminent)
• Test of reasonableness
Where have we come from?
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Framework guidance
CLR 11
Published 2004
UK-wide
All regimes
Tiered approach
• Risk assessment
• Options Appraisal
• Implementation of
remediation
Link to sustainability?
• References in CLR 11
• ‘The goal is to find solutions that identify and deal
with risks from contamination in a sustainable way’
• ‘.. cost-benefit analysis is an inherent part of the
management of environmental risks in a sustainable
way’
• ‘sustainability of the strategy (i.e. how well it meets
other environmental objectives, for example on the
use of energy and other material resources, and
avoids or minimises adverse environmental impacts
in off-site locations, such as landfill, or on other
environmental compartments, such as air and water’
SuRF-UK
• UK-based collaboration of industry, regulators, academics
and consultants
• Established in 2007, following the lead of SuRF (US)
• Independent co-ordination by CL:AIRE
(www.claire.co.uk/surfuk)
• Secretariat has been funded by HCA, with in-kind support
from industry
• Aims
• To produce a framework for assessing sustainable
remediation that is effective, practical and meets
regulatory and industry acceptance in the UK
Where are we now?
• Sustainable remediation
‘the practice of
demonstrating, in terms
of environmental,
economic and social
indicators, that the
benefit of undertaking
remediation is greater
than its impact and that
the optimum
remediation solution is
selected through the use
of a balanced decisionmaking process’
Key Principles
• Protection of human health and the
environment
• Safe working practices (for workers & local
communities)
• Consistent, clear and reproducible decisionmaking
• Record keeping and transparent reporting
(including assumptions & uncertainties)
• Good governance and stakeholder
involvement
• Sound science
SuRF-UK Framework
A Tiered Approach
Indicator Sets
13
Indicator Sets
Environment
Social
Economic
Emissions to Air
Human health & safety Direct economic costs
& benefits
Soil and ground
conditions
Ethics & equity
Indirect economic
costs & benefits
Groundwater &
surface water
Neighbourhoods &
locality
Employment &
employment capital
Ecology
Communities &
community
involvement
Induced economic
costs & benefits
Natural resources &
waste
Uncertainty &
evidence
Project lifespan &
flexibility
Resources
• Framework document
• Review of Indicators report
• Annex 1 SuRF-UK indicator set
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Frequently Asked Questions
Case Study template
Workshop presentations
Webinars/podcasts
• www.claire.co.uk/surfuk
Summary of the Process
• Workshops were held to test and refine indicator
sets using case studies
• Objectives, scope and meanings must be clear to
all parties – a common understanding
• Boundaries to be set at outset – any assessment
will not be unlimited
• Some confusion over the meaning of indicators
• Start simple, assessment should be
proportionate to project scale and sensitivity
• The objective is to achieve a balanced decision
Integration with
developing policy?
• National Planning Policy Framework
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Draft published in July 2011
Presumption in favour of sustainable development
Significant weight on economic development
Removing target for brownfield development
Polarised consultation responses,
• PM promises “appropriate protection”, “clearer definition
of sustainable development”, “simplify the system,
strengthen local participation and secure sustainable
development”
• Publication of final framework expected before end
March 2012
• www.communities.gov.uk
Contaminated land management
• Revised Statutory Guidance
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Draft published in December 2010
Insufficient targeting of high-risk sites
Inconsistent approaches taken by local authorities
Determination process is too long
Remediation standard set too high
Revised contaminated land guidance for England and
Wales laid before Parliament on 7 Feb 2012
• Expected to come into force on 6 April 2012
• www.defra.gov.uk
Statutory Guidance and
Sustainability?
• Objective of the regime includes:
“To ensure that the burdens faced by individuals,
companies and society as a whole are proportionate,
manageable and compatible with the principles of
sustainable development.”
• No other reference to sustainable
• Clause 1.6
“… The authority should take a precautionary approach to
the risks raised by contamination, whilst avoiding a
disproportionate approach given the circumstances of
each case. The aim should be to consider the various
benefits and costs of taking action, with a view to
ensuring that the regime produces net benefits, taking
account of local circumstances.”
Challenges and Opportunities
• Promote voluntary use of the framework
• Conferences/workshops
• Ambassadors
• Feedback loop
• Benefit of submitting case studies?
• Is the framework fit for purpose?
• Are stakeholders satisfied with outcomes?
• Encourage uptake through planning and
contaminated land regimes
– The stage is set to put the framework into practice
Summary
• Balanced decision-making is a scary concept
• Recent consultation responses indicate a lack of trust
• Imperative that a clear, open and inclusive process is
followed to reach and communicate a balanced
decision of environmental, social and economic
factors
• The SuRF UK frameworks is such a process
• Work is continuing, including:
• Encourage the submission of case studies
• Develop guidance on carrying out a first tier
assessment
• Need to widen skill set
• Any other SuRFers out there?
Sustainability Journey?
SuRF-UK Steering Group
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Paul Bardos, r3 environmental technologies
Brian Bone, Bone Environmental Consultant
Richard Boyle#, Homes & Communities Agency
Nicola Harries, CL:AIRE
Alison Hukin, Environment Agency
Naomi Regan#, National Grid
Jonathan Smith#, Shell
• Former members:
• Frank Evans, National Grid
• David Ellis, Du Pont (link with SuRF – USA)
# also representing Soil & Groundwater Technologies
Association (SAGTA)