Environmental Clerk of Works in the UK
Environmental issues, and especially water quality and surface water runoff, are a significant challenge on many construction sites and were the focus of a recent one-day conference conducted by the Association of Environmental and Ecological Clerk of Works (AEECoW) (http://www.aeecow.com/) in Glasgow, Scotland. We’ve extracted some of the “take away points” for developers which emerged from the various workshops and expert presentations:
The EA’s role in construction
‘Pollution prevention starts with knowledge’ (Jake Houghton of the Environment Agency (EA)) with a need to understand your site and check the EA flood risk maps, Met office data and all available environmental data sets. Jake also outlined the importance of understanding the ‘source – pathway – receptor’ process on any site.
A key requirement to aid any contractor is developing a sound Surface Water Management Plan and maintaining it! Focus on separating clean and dirty water and outlining the risks of pollution and how to ameliorate them through basic or passive methods (i.e. settlement lagoons).
Regulatory position statements
Regulatory position statements are when the EA will not require you to obtain a permit to carry out certain activities. The example of ‘temporary dewatering from excavations to surface water’ (here) is key for contractors; it outlines guidance when dewatering rainwater and infiltrated groundwater is required.
More to follow on this guidance document and the key conditions to adhere to.
Control and Treatment options for surface water management – SEPA’s Construction Site Licences.
Key points for any ECoW or contractor at the start of a construction project regarding the initial risk assessment is reducing the exposed soils, amount of surface water runoff and mixing of soils and surface water. Followed by outlining your treatment options (i.e. attenuation, swales and/or pumps) and relating back to Jake Houghton’s earlier advice ‘pollution prevention starts with knowledge’; i.e. know your site!
A Controlled Activities Regulations (CAR) licence (to control surface water discharges) will be required when the construction site consists of an area greater than 4 hectares, or a linear development greater than 5km, or has an area of more than 1 hectare or any length of more than 500 metres (slope dependent).
A key requirement of the CAR licence for contractors before work begins is the production of a Pollution Prevention Plan. Items that need to be understood include:
- What’s the land and its area?
- What’s your construction activity?
- Who is the contact (and responsible)?
- What are your pollution risks?
- How will you prevent pollution?
- How will you manage runoff?
- What happens when something goes wrong?
- Whose checking adherence and/ or enforcing the plan works
As such it is a key that contractors engage with an experienced environmental professional (or ECoW) as early as possible to outline the above before attending site. This was reflected in Patrick Keenan’s (RJ McLeod) presentation also regarding construction site licences in which he emphasised the importance of early ECoW involvement.
The SEPA guidance
You can access The SEPA guidance document on construction site licences, (here).
If you’d like more information or advice about any of the above, please contact us at info@bear-environmental.co.uk
