It may be that we have a difference in terminology going on between developers and regulators?
the issue we have is in relation to planning applications, we are under pressure to limit the number of conditions we place on a consent - and these conditions must be capable of being met -
so we generally planning applications condition for
1) a SI report (inc Risk assessment) - the intention is this will identify the problems on a site which require to be addressed.
2) A RMS - which specifies the works necessary to mitigate the risks identified in the SI and RA. - We think a verification plan (i.e. how the works will be shown to have been completed adequately) would be in the RMS, and finally
3) a Verification report (VR) which documents the works set out in the RMS have been adequately completed and verified in accordance with the RMS. - there is scope for deviations from the RMS to be included in the VR, however there needs to be some statement that all the works completed fulfil the RMS objectives.
the issue is if a RMS delivered to satisfy condition 2 is not specific in the works to be done, how can the regulator be satisfied the remedial works proposed adequately deal with the issues which have been identified at the SI.RA stage.
The only point of regulatory contact with the project is when the VR is submitted - and if the works are not satisfactory, it is too late as buildings are built.
In our opinion, the Remediation Options Appraisal process (which concluded with the development of a RMS) - as per Chapter 3 of CLR11 - would catalogue much of the necessary RMS justifications - but ROA are not being carried out. The RMS we see are essentially direct copies of outline remedial strategies from SI/RA outputs.
We have seen crazy "RMS" which recommend 600mm cover system to protect against "shallow soil contamination" - but the site is being raised by a metre for flooding - so 600mm cover is being achieved by other means - likewise, we have seen 600mm cover being recommended for contamination in shallow soils which are 2m above FGL - so the client has removed 2.6m of soil (well into clean natural soils) and placed a 600mm cover system on clean natural soils - bonkers!
likewise, a cut/fill exercise could bring deep contamination to a development surface
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