Presently, for a majority of contaminates, there are no endorsed standards or guidelines within Australia that define, for each category of land use, safe levels of soil contamination. What we do have within the National Environment Protection Measures Act 1998 (NEPM Act) guidelines is an adopted remediation criteria recommending investigation levels. Our suggestion is this investigation criterion is far too conservative and not well adopted or able to properly adept to manage health and environmental risks.
Posted on January 6, 2013 by co2land, Contaminated Land – Obligations to manage – was written to help the reader to understand that managing the environment means many things and it is not necessarily so that moral decisions will be made. From that story it follows that a natural discussion point is to now look at the remediation challenges, or if you prefer to call it – appropriate actions, and the point is made that to manage contamination the issues may involve: risk management activities, including actions to limit exposure to contaminates; remediation, such as physical containment, capture and on-site treatment, or removal/offsite for disposal; or whatever combination of above. In today’s political climate it is unlikely a government officer would go along with addressing the challenges unless due diligence investigations and factoring the results into a cost-benefit analysis was done ‘appropriately’. As a Carbon Manager, we might say extensive due diligence investigations and cost-benefit analysis has cost and time implications that science clearly indicates we do not have the luxury to indulge into – the earth as we know is dependent on our actions.
Notwithstanding the urgency matter, ‘real’ remediation challenges include managing the uncertainty associated with the costs of remediation, remember it was said investigative sampling could only provide an estimate of the actual problem (the nature, extent and concentrations of what is the contaminant(s)). Therefore any property management decision can attract significant cost risk when considering changes to land use. To recant the start of this discussion it was said recommendations are part of the NEPM Act and the conservative responses that will be elicited are not strong. It may be that the data available is part of the problem and that needs to be addressed in a more robust or targeted way.
CO2Land org noted that the federal Department of Finance and Deregulation has a number of areas responsible or have responsibility pertinent to management of contaminated land and wonders if it might be data collection that is the greater weakness in terms of the abilities for adequate and timely responses. Stronger more targeted data collection could be better used to quantify the risk and might lessen the likelihood of ‘excessive’ or redundant analysis on a project-by-project basis. The potential is to save money too!
We will expect we will increasingly see this approach being implemented and would applaud where issues such as uncertainty is reduced; improved decision making processes are covered off; and more efficient funding approval processes are followed. We believe additional benefits could accrue and if it is transparent shared lessons learnt and reports could give improvement in practice and the moral and the legal be much the same outcome.