By Legal Futures Associate Future Climate Info
The Environment Agency (EA) has published an update to the Model procedures for the management of land contamination (CLR11).
The updated online guidance is built on the principles of CLR11 and the scope, purpose and the framework remains the same.
The original guidance began as a research document back in 2004 and was quickly adopted as the de facto guide for managing the risks from land contamination. In this time it has not been updated, so this is a welcome enhancement that makes it more accessible for all.
Single Remediation Strategy Format
The structure is shorter and more simplified. The explanation of the remediation process has been improved. There is now an emphasis on developing and producing a single remediation strategy, rather than just working through the stages.
This means that the later stages and tiers have been revised and reordered. Stage 2 now focuses on reviewing options appraisal, while stage 3 is about remediation and verification.
It also includes a Remediation options applicability matrix. This is a tool to help indicate the broad capabilities of a remediation option and covers common methods that are generally available for particular contaminant-media type combinations.
Better Look and Feel
The look, feel and usability of the guidance have also been upgraded:
- Technical language, terminology and content has been updated, explained and retained where necessary – it is now suitable to novice and professional alike.
- It complies with new accessibility laws – such as compatibility with screen readers, web based, clear and concise.
- Repetition and general background information has been removed to meet GOV.UK publishing requirements
- It is now more user focussed, shorter and easier to understand
- Information on next steps is much clearer, whilst retaining the same referencing system.
The EA is actively seeking feedback so that the new guidance is acceptable to both environmental practitioners and regulators on the technical content and structure for a period of 6 months.
Once the feedback has been incorporated, the existing CLR11 document will then be withdrawn, to avoid confusion over which version to use. None of these changes affect the original purpose of CLR11 or any existing or planned contamination projects.
The changes have been endorsed by Tim Champney, our Risk and Consultancy Manager:
“From a first glance, the LCRM guidance appears to offer a more intuitive approach to the risk management principles. I expect that the improved accessibility of the guidance will make the market at the early stages of the risk assessment process more inclusive and competitive, which can only be a good thing, whilst helping to improve the quality and consistency of those services offered. Future Climate Info will be actively engaging with the Environment Agency to provide our support and contribution to the import feedback process before the final withdrawal of CLR 11 at the end of 2019.
Our resident Specialist in Land Condition (SilC), Commercial Director, Chris Taylor also said:
“The new guidance seems an excellent step forward, simplifying CLR11 to make the key content more manageable and easy to understand by a wide range of property professionals.
The online format enables quick navigation but still retains the key reference documents which experts may need to refer to during the risk management process. I’m sure there will be some changes following feedback from user groups such as SiLCs, but the current guidance is a solid first step and we look forward to further improvements.”
We will be using the framework, together with additional feedback on best practice through our professional links with CL:AIRE, IEMA and CIWEM to support our opinions applied to both our contaminated land risk assessments and FCI appraisals for both residential and commercial property.