All things considered, tolerable residual risk, given the redirection of funding away from Part 2A may be about to become a pretty emotive and wider issue than for the LPA?
Ruth
Ruth Willcox
Environmental Protection Officer
Office of the Director of Public Health
Plymouth City Council
Civic Centre
Plymouth
PL1 2AA
T +441752304154
E [log in to unmask]
www.plymouth.gov.uk
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Matt Rhodes
Sent: 12 May 2014 11:37
To: [log in to unmask]
Subject: Re: C4SL
Chris
Thanks for your comments.
The responsibility for ensuring safe development rests with the developer, however the determination of what is "safe" rests with the LPA. Hence the "as a minimum" phrase. It is for each LPA to decide how much, in its reasonable view taking account of the new use and other relevant considerations, residual risk it is prepared to tolerate.
This somewhat misses the point of my question though.
Where a ph2 goes through the risk assessment process using generic assessment criteria chosen by the consultant (and hopefully agreed by the LPA) is it correct to adopt a second set of criteria for the ph3?
Lets remember what generic assessment criteria are, they are conservative values that should give a great deal of confidence that the site does not present a risk, allowing the risk assessment to be simplified so the need for site specific criteria can be avoided. They are not in themselves remediation values, however if you want to come up with a remediation value rather than relying on GACs you will need to undertake a site specific assessment.
LA contaminated land officers should not be making developers remediate to a GAC level, but the developer may find it expedient to do this to avoid the expense of developing site specific values . That is the choice the developer is faced with as part of their responsibility for ensuring safe development.
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