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Soil Erosion & Sediment Control Internal Management Systems Review
Report Template & Action Plan
Introduction
The following document is a template that can be used by Councils undertaking an ESC Internal Management Systems Review. This document can be populated as the Council follows the Steps outlined in the ESC Internal Management Systems Review - Step-by-Step Guideline (download from Water by Design Webpage). Each Step will prompt Council to collect relevant data to input into this template so that once completed it will provide a summary of the current situation with a plan for action. Results in this report should ideally be retained so it can be used as a baseline for comparison with any future investigations to demonstrate the progress and success of implemented changes. Council may choose to edit any part of this document to reflect local issues and relevance. For example, a blurb could be included on this front page that covers the local situation and the background that led to this review, along with Council’s title and logo etc. Councils may also like to change or add its own parameters to the data collection tables. Please note this is a guide only, and the Steps are purely suggestions. As each Council will have its own issues and priorities the focus should be on what is locally relevant and important.
If you have any questions regarding the use of this document please contact Water by Design which is a program of Healthy Waterways Ltd: [email protected] or telephone (07) 3177 9100.
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT)
Step 2: Rapid Desk Top Assessment
Step 3: ESC Policy Review
Step 4: ESC Plan Review
Step 5: ESC Compliance Process Review
Step 6: Staff Surveys
Step 8: Develop an Action Plan
Step 7: ESC Score Card
Step 9: Annual Review
Table of Contents
Introduction...........................................................................................................................................................1
Table of Contents..................................................................................................................................................2
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT).............................................................3
Internal Review Team........................................................................................................................................3
Managerial Support...........................................................................................................................................3
Step 2: Rapid Desk Top Assessment......................................................................................................................4
Step 3: ESC Policy Review......................................................................................................................................5
ESC Policy & Guideline Review...........................................................................................................................5
Training and Education......................................................................................................................................6
Step 4: ESC Plan Review.........................................................................................................................................7
Step 5: ESC Compliance Process Review................................................................................................................8
ESC Site Inspection Results................................................................................................................................8
ESC Site Inspection Photographs.......................................................................................................................8
Desk-Top Compliance Records Review..............................................................................................................9
Step 6: Staff Survey..............................................................................................................................................10
Instructions:.....................................................................................................................................................10
Development Assessment Staff Survey Template............................................................................................11
Development Assessment Staff Survey Results...............................................................................................14
Compliance Officers Survey Template.............................................................................................................15
Development Assessment Staff Survey Results...............................................................................................16
Step 7: ESC Internal Management Systems Score Card for Councils...................................................................17
Step 8: ESC Action Plan........................................................................................................................................24
Summary & Conclusions......................................................................................................................................27
2
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT)
Internal Review TeamAn internal review team was established on (insert date) to review the internal management systems relating to Erosion Sediment Control. The members are outlined in Table 1 below. (include any expert consultants, and external stakeholders involved eg Healthy Waterways, EPA etc)
Table 1: Members of the Internal Review Team
Name Department Role Responsibility
Managerial SupportManagerial support was given on the (insert date) through the (insert meeting/memo/committee etc that gave support for review to occur & attach supporting documentation if required).
3
Step 2: Rapid Desk Top Assessment
The following is a summary of the outcomes from ESC Rapid Assessment (the full Audit Tool Template can be download from the Water by Design website).
Table 2: ESC Rapid Assessment Summary
Features of a best practice ESC program
Current level of performanceVery Poor Very Good
Strengths / Weaknesses of the current program
Recommended actions to improve performance
[please tick one]
1. Political and executive support
2. Policy, planning controls and development assessment
a) Ddevelopment assessment and building approval process.
b) Council’s own ESC construction and maintenance activities.
3. Compliance & Enforcement
4. Management systems
5. Resourcing
6. Awareness of ESC
a) Awareness within Council
b) Awareness within the broader community
7. Specialist training
8. Audits to track performance over time
9. Technology and innovation
10. Incentives
4
Step 3: ESC Policy Review
ESC Policy & Guideline ReviewThe documents outlined in Table 3.1 were reviewed against ESC best practice guidelines. A summary of the outcomes of this review are presented below.
Table 3.1: ESC Policy and Guideline Document Review – Data Collection Sheet
Is the document easily accessible and utilized by staff/industry?
Does the document reflect or reference Best Practice ESC IECA Manual? Does it go above
and beyond? Provide Comments:
Other Comments/Issues (provide a short summary of any issues with the document - more
detail may be provided in a separate report)
RecommendedFollow-up Actions
Planning Scheme Policy, Codes & associated ESC Guidelines
Standard Conditions for assessable development
ESC self assessable codes/guidelines for lots < 2500m2
Checklists/procedure for assessing ESC Plans
Development inspection and enforcement procedures document for assessable development
Development inspection and enforcement procedures document for building sites /
Checklist for undertaking ESC Site Inspections
Fact sheets/educational material
5
Training and EducationThe following details staff and industry qualifications in relation to ESC expertise.
(This Table provides a suggested template for the Council to record Staff and Industry ESC qualifications. Such a register might be used to record internal staff training and to recognise training needs. It may also be used to determine whether an external consultant is suitably qualified to submit plans or whether a contractor is suitably qualified to install ESC measures).
Table 3.2: Template for Register of ESC Suitably Qualified Persons (internal and external)
Name Employer Position Role in ESC Process (Compliance/DA/Plan Writer/ Plan Implementer)
Qualification
(inc date obtained)
Training undertaken
Further Training Required
6
Step 4: ESC Plan Review
(insert number of plans reviewed) ___ ESC Plans were reviewed to determine compliance with Council policy and best practice standards.
Table 4: ESC Plan Review – Data Collection Sheet
# Summary of Comments, Issues & Recommendations
Number of developments reviewed as part of this audit
How many of these developments had ESC Plans reviewed/approved by Council
How many of these ESC Plans were compliant with policy/guidelines/best practice standards
How many of these ESC Plans had condition of approval that were compliant with policy/guidelines/best practice standards
How many of these ESC Plans were on high risk sites (dispersive soils, steep slopes, acid sulphate soils etc)? Of these high risk sites how many Plans had additional controls / conditions to address the risk.
How many of the developments were / will be open during the wet season? Of these developments how many had ESC Plans with additional controls / conditions to address wet season risks
How many of these ESC Plans were signed off by a suitably qualified person/CPESC
*ESC Best Practice refers to the International Erosion Control Association - Best Practice Erosion & Sediment Control Manual http://www.austieca.com.au/
7
Step 5: ESC Compliance Process Review
ESC Site Inspection Results(insert number of developments inspected) ___ developments were inspected to assess compliance with site specific ESC Plans.
Table 5.1: Compliance Review – Summary of Site Inspection Results
# Comments
Number of Developments inspected
Number of Developments that fully complied with ESC plans and controls were effectively managing erosion and sediment
Number of Developments that fully complied with ESC plans, but controls were not effectively managing erosion and sediment
Number of Developments that mostly complied with ESC plans but had a few minor non-compliances
Number of Developments that mostly did not comply with ESC plans and had major non-compliances
ESC Site Inspection PhotographsThe following are photographs of compliant and non-compliant construction sites.
(insert images taken of site inspections here)
8
Desk-Top Compliance Records ReviewCompliance procedures and documentation were reviewed for (insert number of developments)___ developments.
Table 5.2: Compliance Review - Desk Top Assessment
# Comments
Number of developments inspected that have had previous non-compliances documented?
Number of developments issued with a written notice or regulatory notice to address a minor non-compliance in the last 12 months
Number of developments with major non-compliance documented
Enforcement tools used to rectify a major non-compliances – specify:
Effectiveness of enforcement tools – non-compliance rectified within a week, within a month, not at all.
Over the last 12 months how many of the following have been issued for ESC non-compliance (total for all developments with ESC plans approved by Council):
o Written request
o Show cause notice (SPA)
o Stop works notice (SPA)
o Action under EPA
What time frames have generally been given for developers to fix a non-compliance?
9
Step 6: Staff Survey
Instructions:The following are Staff Survey Templates that can be used to collect data from DA Assessment and Compliance Officer Staff on the topic of ESC assessment and compliance.
There are a number of ways the survey could be delivered to staff, however it is recommended that a survey delivery and collation program such as Adobe FormsCentral or Survey Monkey be used so that the results can remain anonymous, be automatically collated, easily downloaded and analysed. The following Staff Survey Templates can be downloaded from the WbD website in the Adobe FormsCentral Format. If you have the FormsCentral Program, use it to open the files, edit the survey content as needed and distribute the survey to relevant staff. Once the staff have completed the survey their responses will be automatically collated by the program and can then can then be downloaded into excel or pdf for further analysis. The FormsCentral Program can be downloaded from http://success.adobe.com/en/na/sem/services/1109_5958_formscentral.html for a nominal fee of $15 per month.
If you do not wish to use a survey collation program you could alternatively cut and paste the text below into a separate word document and deliver it to staff via email or hardcopy. Responses can then be manually collated and analysed. However if this method is chosen, consider how the anonymity of the survey will be maintained, and factor in the length of time data collation may take.
Once collated, the responses can then be summarised and inserted into this ESC Review Report Template. You may like to present summarised data in graphs and/or tables, and extrapolate key ideas and anonymous comments.
10
Development Assessment Staff Survey Template
Purpose: The following survey has been designed to provide staff involved in the assessment of Erosion & Sediment Control Plans with the opportunity to comment on the ESC policy & assessment process, and to seek suggestions for improvement. Please note that survey results will remain anonymous and will only appear in reports as pooled statistical results, or as anonymous recommendations for improvement.
Questions:
1. Please indicated your involvement in the ESC Plan Assessment processes (more than one item can be selected):
Assessing / Reviewing ESC Plans as part of the Development Assessment process
Writing Conditions of Approval for ESC Plans
Preparing / informing ESC Policy associated with Planning Schemes
Other
2. Why do you think Erosion & Sediment Control is important?
To protect freshwater and marine environments
To protect stormwater infrastructure and reduce infrastructure maintenance costs
To improve social values and use of waterways and coastal environments, for example by improving aesthetics and recreational experiences (eg swimming, fishing)
Other
3. How do you rate your qualifications and knowledge of ESC?
Excellent (certified practitioner (CPESC), completed ESC training/up-skilling activities, and feel confident interpreting and assessing plans, writing conditions and providing advice to planning, engineering and industry)
Good (completed ESC training and feel confident interpreting plans and providing advice)
Average (completed ESC training and feel somewhat confident interpreting plans and providing advice, however some extra training would improve confidence)
Have not completed ESC training and/or do not feel confident interpreting plans and/or providing advice
In which areas of ESC would you like to improve your skills & knowledge? _______________________
4. How would you rate ESC performance in the region:
Excellent (better than best practice)
Good (best practice)
Poor (below best practice and generally non-compliant)
Unsure
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5. Do you feel Council ESC Policies comply with best practice standards - Best Practice Erosion & Sediment Control Manual, produced by the International Erosion Control Association (IECA).
Yes
No
Unsure
Comments:_________________________________
6. How would you rate compliance of submitted ESC Plans with best practice standards:
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
Comments:________________________________
7. Overall, how would you rate the quality of submitted ESC Plans.
Excellent
Good
Average
Poor
Unsure
Comments:_______________________________
8. Does Council insist that submitted ESC Plans are prepared by a suitably qualified professional (CPESC)?
Yes
No
Comments:_______________________________
9. Does Council have a risk assessment process in place to identify ‘high-risk projects’ that require a high level of ESC planning and management?
Yes
No
Unsure
If yes, what type of additional controls or conditions are placed on high risk development sites? (eg less area opened at once, larger sediment basins, reduce earthworks during wet season, increased % of stabilisation / ground cover?) ____________________________________________________
12
10. Do you feel Conditions of Approval for ESC Plans are in accordance with best practice standards?
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
If not, do you have ideas on how ESC Conditions could be improved? Would you like to make any other comments regarding ESC Plan Conditions? __________________________________________
11. Please provide comments on how you think the ESC Plan assessment process can be improved to achieve better quality plans and on-ground outcomes? _________________________________________
12. Do you feel there is strong political and executive support for establishing a high standard of ESC across the region?
Yes
No
Unsure
Comments:____________________________________
13. Are there any other comments you would like to add? _________________________________
14. This survey is part of an Internal ESC Management Systems Review with the ultimate aim of improving ESC implementation across the LGA. Do you have any comments on how the Internal Review Process or this survey could be improved? Are there any other questions you feel need to be asked/answered as part of this process? __________________________________________________________________
_______________________________________________________________________________
13
Development Assessment Staff Survey Results(insert the pooled statistical survey results for reporting purposes eg graph, tables etc)
14
Compliance Officers Survey Template
Purpose: The following survey has been designed to provide staff involved in development compliance with the opportunity to comment on ESC compliance process matters, and to seek suggestions for improvement. Please note that survey results will remain anonymous and will only appear in reports as pooled statistical results, or as anonymous recommendations for improvement.
Questions:
1. Please indicated your involvement in ESC Compliance on development sites (more than one item can be selected):
Development Compliance Officer
Environmental Health Officer
Building Compliance Officer
Engineer
Planner
Other _____________________
2. Why do you think Erosion & Sediment Control is important?
To protect freshwater and marine environments
To protect stormwater infrastructure and reduce infrastructure maintenance costs
To improve social values and use of waterways and coastal environments, for example by improving aesthetics and recreational experiences (eg swimming, fishing)
Other _____________________
3. How do you rate your qualifications and knowledge of ESC?
Excellent - Certified practitioner (CPESC). Completed ESC training/up-skilling activities. Feel confident interpreting plans, identifying compliant/non-compliant sites, and taking enforcement action when necessary.
Good - Completed ESC training. Feel confident interpreting plans, identifying compliant/non-compliant sites and taking enforcement measures when necessary
Average - Completed ESC training. Feel somewhat confident interpreting plans, identifying compliant/non-compliant sites and taking enforcement measures when necessary
15
Have not completed ESC training and/or do not feel confident interpreting plans, and/or identifying compliant/non-compliant sites, and/or taking enforcement action
Other _____________________
In which areas of ESC would you like to improve your skills & knowledge? _________________
4. How would you rate development site compliance with approved ESC Plans generally across the region:
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
Comments: ________________________________________________________________________
5. How would you rate the effectiveness of ESC on development sites where plans have been implemented?
Effective (run-off from site is virtually clear, erosion not obvious)
Medium effectiveness – (run-off from site is a bit muddy, erosion not obvious)
Not effective – (few controls in place, erosion is obvious, run-off is brown/muddy)
Comments: ________________________________________________________________________
6. Does Council have a self-assessable code for developments under 2,500m2?
Yes
No
Unsure
If so, do you know if this Code is implemented and complied with by the building industry? Could you recommend how compliance may be able to be improved?__________________________________
7. What tools does Council use to deal with ESC non-compliance? How regularly are enforcement tools used, for example on-the-spot fines, stop work notices and prosecutions for clear breaches of ESC development conditions?
Every time a non-compliance is found an enforcement tool is used
Most of the time (80% of the time)
16
Some times (<50% of the time) and only if there is a serious breach
Enforcement tools for non-compliance have been used very little or not at all in the last 12 months
Comments:_____________________________________________________________________
8. If Council does not regularly use enforcement measures to address non-compliance, please outline the measures that Council uses to achieve developer compliance. Have these measures been effective? How long does it usually take for a developer to address a non-compliance using these measures? How do you think this process could be improved? _________________________________________________________________
9. Do you feel there is strong political and executive support for establishing a high standard of ESC across the region?
Yes
No
Unsure
Comments:_______________________________________________________________________
10. Do you feel Council provides sufficient resources (staff, funding, training etc) and support to adequately undertake site inspection and apply regulatory / enforcement tools where necessary.
Yes
No
Unsure
Comments:_______________________________________________________________________
11. What do you feel are the barriers to ESC implementation and do you have any suggestions on how these could be overcome? _______________________________________________________________________
12. What are the current drivers that encourage ESC implementation? _______________________________
13. This survey is part of an internal ESC management systems review with the ultimate aim of improving ESC implementation across the LGA. Do you have any comments on how the Internal Review Process or this survey could be improved? Are there any other questions you feel need to be asked/answered as part of this process?
17
Development Assessment Staff Survey Results(Insert the pooled statistical survey results for reporting purposes)
18
Step 7: ESC Internal Management Systems Score Card for Councils
The following Score Card summarises Council’s overall ESC performance as determined by the results from the Internal Review Process.
A – above best practice; B – best practice C – Common practice, D/E-practices that are unacceptable by industry and community standards and/or do not meet regulatory requirements
Table 7.1: ABDC Score Card - Council Processes for ESC Policy, Assessment, Approval and Compliance
Item A B C D/E Score
Score 5 4 3 1
Policy Score
xTotal
ESC Policy/Guidelines/
Standard
ESC Planning Scheme Policy meets SPP requirements and reflects / references IECA.
ESC Planning Scheme Policy goes beyond best practice where necessary to suit climatic conditions and achieve WQ objectives (eg stop works during wet season, regulate area and period of exposure)
ESC Planning Scheme Policy meets SPP requirements and reflects or references IECA.
Planning scheme integrates SPP requirements.
Not consistent with SPP or best practice guidelines.
1
Erosion Risk Assessment
Council has erosion risk maps for whole of LGA.
Council requires submitted ESC plans to assess erosion risk.
Council has soil class maps of LGA.
Council requires submitted ESC plans to assess erosion risk.
Council requires submitted ESC plans to assess erosion risk
Council does not undertake erosion risk assessments and does not require submitted ESC plans to assess risk.
1
Assessment
ESC Plan Assessment Qualified Staff ensure all submitted plans Qualified Staff ensure all Staff assess plans against Council does not require 2
19
are consistent with the Planning Scheme. Inconsistent plans are not approved.
Council provides guidance/procedures to industry on how to develop ESC plans for development sites.
Council provides staff with ESC plan assessment procedures and training.
submitted ESC plans are consistent with the Planning Scheme. Inconsistent plans are not approved.
Council provides guidance/procedures to industry on how to develop ESC plans for development sites.
Planning Scheme. ESC plans to be submitted to Council and does not provide guidance to industry regarding the minimal requirements
Qualifications of ESC Plan Writer
Council only accepts plans from suitably qualified professionals with CPESC qualifications.
Council only accepts plans from suitably qualified professionals as defined by Council Guidelines (eg completed an accredited ESC Course)
Council accepts plans from professionals (eg engineers) who may or may not have specific ESC qualifications.
Council has no requirements for ESC plan writers to be qualified 1
Qualifications of Council ESC Assessing Officers
Staff assessing, approving and conditioning ESC Plans are CPESC qualified
Staff assessing, approving and conditioning ESC Plans have a degree in Engineering, Environmental Science or related discipline, and have completed specific ESC training.
Staff assessing, approving and conditioning ESC Plans have a degree in Engineering, Environmental Science or related discipline but are not required to have completed specific ESC training.
Staff assessing, approving and conditioning ESC Plans are unqualified.
1
ESC Plan Conditions Conditions are consistent with, and supported by best practice guidelines (IECA, 2008). Conditions are practicable, measurable, and consistent for all developments.
Conditions go above best practice guidelines on high risk sites to achieve WQ guidelines (eg stop works during wet season, regulate area and period of exposure)
Conditions are consistent with, and supported by best practice guidelines (IECA, 2008). Conditions are practicable, measurable, and consistent for all developments.
Conditions are consistent with SPP but do not go beyond this nor do they incorporate IECA recommendations.
ESC Conditions are not consistent with SPP or IECA, are not consistently applied to all developments, and are not specific / measurable. 1
Compliance
20
Development Compliance with Best Practice Standards
Majority of developments (>80%) comply with approved plans, best practice standards, and install additional controls where needed.
Majority of developments (>80%) voluntarily comply with approved plans
Some developments (<50%) voluntarily comply with approved plans
Few developments (<25%) voluntarily comply with approved plans 2
Development Compliance Run-off Water Quality (Mg/L) Guidelines
50mg/L – Majority of developments (>80%) comply with 50mg/L target
<100mg/L – Majority of developments (>80%) have run-off concentrations of <100mg/L
<250mg/L – Majority of developments (>80%) have run-off concentrations <250mg/L
>250mg/L – Majority of developments (>80%) have run-off concentrations of >250mg/L
2
Compliance Inspections and Enforcement
Council routinely and frequently inspects construction / development sites to assess legislative compliance, and follows-up on complaints.
Council strategically use enforcement tools such as on-the-spot fines, stop work notices and prosecutions for clear breaches of ESC development conditions and Environmental Protection Act s440ZG.
Council has a track record of successfully enforcing ESC conditions and regulations, as well as procedures, systems and cultures that support successful enforcement action.
Council routinely and frequently inspects construction / development sites to assess legislative compliance, and follows-up on complaints.
Council strategically use enforcement tools such as on-the-spot fines, stop work notices and prosecutions for clear breaches of ESC development conditions and Environmental Protection Act s440ZG.
Council undertakes inspections of development sites, however rarely uses enforcement tools to address clear breaches of ESC development conditions and EPA 440ZG.
Council does not undertake investigations to monitor development compliance and does not utilise enforcement tools.
2
Monitoring For developments that are large scale and/or high risk and/or have sediment basin/s:
- Council conditions the developer to report stormwater quality discharge monitoring and ESC plan compliance regularly to Council. Water Quality monitoring is undertaken by a third party at the expense of the
For developments that are large scale and/or high risk and/or have sediment basin/s:
- Council conditions the developer to report stormwater quality discharge monitoring and ESC plan compliance regularly to Council. Water
For developments that are large scale and/or high risk and/or have sediment basin/s:
- Council conditions the developer to report stormwater quality discharge monitoring and ESC plan compliance to
Council does not require developers to monitor stormwater quality discharge from their sites.
1
21
developer. Council follows-up to ensure monitoring reports are submitted and conditions are being complied with.
- In additional, the developer financially contributes to Council’s regional water quality monitoring program, which includes WQ monitoring during/after rainfall events downstream of large developments and high risk sites.
Quality monitoring is undertaken by a third party the expense of the developer. Council follows-up to ensure reports are submitted and conditions are being complied with.
Council.
- However Council does not actively follow-up to ensure reports are submitted and conditions are being complied with.
Compliance staff qualifications
ESC Compliance Officers are CPESC qualified
ESC Compliance Officers have completed specific ESC training and have a good understanding of ESC principles.
ESC Compliance Officers have some understanding ESC principles.
ESC Compliance Officers have not completed specific ESC training and do not have a good understanding of ESC.
1
Managerial Support
Political and Executive Support
There is strong support for establishing a high standard of ESC across the city / shire at political and executive levels in Council.
Front-line staff feel supported to insist upon a high standard of ESC during development assessment, enforcement, construction or maintenance activities. This has translated to a high degree of ESC implementation.
There is some support for establishing a best practice standard of ESC across the city / shire at political and executive levels in Council.
Front-line staff feel supported to insist upon a best practice standard of ESC during development assessment, enforcement, construction or maintenance activities.
There is some support for establishing a high standard of ESC across the city / shire at political and executive levels in Council.
Front-line staff would like to feel more supported to insist upon a high standard of ESC during development assessment, enforcement, construction or maintenance activities.
There is little support for establishing a high standard of ESC across the city / shire at political and executive levels in Council. Front-line staff do not feel supported and as a result find it difficult to insist upon a high standard of ESC during development assessment, enforcement, construction or maintenance activities.
2
Resourcing Council provides sufficient staff and funds to adequately assess plans, routinely
Council provides sufficient staff and funds to assess plans,
Council provides some resources for plan
Council does not provide sufficient staff and funds to
2
22
inspect construction sites, and apply regulatory / enforcement tools where necessary. This has translated to a high degree of ESC implementation.
routinely inspect construction sites, and apply regulatory / enforcement tools where necessary.
assessment and compliance, however staff feel more support is needed to improve the implementation of ESC.
adequately assess plans, routinely inspect construction sites, and apply regulatory / enforcement tools. As a result ESC is not being implemented by industry.
Awareness
Awareness within Council (e.g. amongst councillors, executives, development assessment officers, enforcement officers, construction and maintenance staff, etc.), and awareness within the broader community (e.g. local builders, homeowners, developers, contractors).
Council has adequate initiatives in place to ensure these people have a good understanding of the significance of erosion and sediment as a threat to healthy waterways, what can be done to manage erosion risk, and the relative benefits vs costs of ESC. This has translated to a high degree of ESC implementation.
Council has initiatives in place to educate these people on the significance of erosion and sediment as a threat to healthy waterways, and what can be done to manage erosion risk.
Council has a basic community and industry ESC education program (eg educational information available on Council website, leaflets etc.), however there is still a low level of awareness of the threat erosion and sediment pose to waterways.
Council does not have any programs in place to raise awareness of the importance of ESC.
1
Total Score
Score Conversion:
A B C D E
90-100 70-89 50-69 30-49 <30
23
Table 7.2: ABDC Score Card – ESC Management Processes for Council Infrastructure Projects
Council ESC Performance
(for Council’s own construction and
maintenance activities)
A
(4)
B
(3)
C
(2)
D
(1)Score
Policy and procedures Council has policies and procedures in place to ensure ESC standards on Council’s own building, construction and maintenance works represents best practice and set a positive example for local stakeholders.
The responsibility for managing ESC on Council sites is clear.
Meaningful incentives / disincentives are in place to ensure Council’s construction and maintenance staff set a good example.
Council has policies and procedures in place to ensure that ESC standards on Council’s own building, construction and maintenance works represents best practice and set a positive example for local stakeholders.
The responsibility for managing ESC on Council sites is clear
Council some policies and procedures in place to ensure that ESC standards on Council’s own building, construction and maintenance works meet Environmental Protection Act requirements.
Council does not implement policies or procedures to ensure ESC is undertaken on Council’s own building, construction and maintenance works.
Planning Council produces ESC plans for all their own earthwork/construction activities.
Plans are prepared by a suitably qualified professional (i.e. a Certified Professional in ESC).
Council develops ESC concept plans prior to letting a project for tender.
Council produces ESC plans for all their own earthwork/construction activities.
Council only produces ESC plans for its own earthwork/ construction activities when the sites have a high erosion risk
Council does not produce ESC plans for its own earthwork/construction activities.
Implementation ES Controls are implemented, monitored and maintained on all sites.
Changes are made to controls as needed to adjust to changing site conditions.
Site foreman is appropriately trained and qualified to implement ESC Plans.
ES Controls are implemented, monitored and maintained on all sites.
Changes are made to controls as needed to adjust to changing site conditions.
Site foreman is appropriately
ES Controls are implemented only on high risk sites
ES Controls are not implemented, monitored and maintained
24
Council undertakes water quality monitoring during/after rainfall events downstream of works.
trained and qualified to implement ESC Plans.
Revegetation/Stabilisation Comprehensive site rehabilitation plan developed for all sites
Council ensures all works undertaken by or on behalf of Council are adequately revegetated/stabilised directly after works are complete.
Most Council work sites (including all high risk sites) are adequately revegetated/stabilised,.
Only sites with high erosion risk are adequately revegetated/ stabilised.
Council work sites are not being adequately revegetated/ stabilised.
Score Conversion:
A B C D
15-16 11-14 7-10 <7
25
Step 8: ESC Action Plan
Table 8: ESC Action Plan Template
ItemProblem
(as identified by review)
Action
(the following are suggestions – Council may edit actions to suit its needs)
Person responsible to complete and report on
ActionTimeframe Resources
requiredManager Sign-off
Annual Review
Have actions been completed within the timeframe. Note any
challenges or deviations from Plan.
Policy
ESC Policy/Guidelines/
Standard
Amend documents to current meet best practice guidelines. Go beyond best practice where necessary to suit climate conditions and achieve WQ objectives (eg to address steep sites, dispersive soils, heavy rainfall)
Erosion Risk Assessment Undertake and publish erosion risk assessment maps. Produce a clear procedure for developers to undertake erosion risk assessments (eg IECA procedures)
Assessment
ESC Plan Assessment Develop a procedure for ESC assessment that clearly sets out:
- Who in Council is responsible for assessing, preparing information requests, preparing conditions and approving ESC Plans in accordance with best practice standards
- Resources required to achieve adequate ESC assessment
- An ESC Plan Assessment Checklist to ensure plans meet best practice
- Other .....
Qualifications of ESC Plan Writer
Depending on the issue actions might include:
- Write and implement a policy to ensure Council only accept plans from suitably qualified professionals.
- Gain managerial sign-off and support to refuse plans not prepared by a suitably qualified person
- Provide regular training to local industry
Qualifications of ESC Plan Assessing Officers
Identify training and qualification gaps and provide training to relevant staff. (define qualifications required)
ESC Plan Consent Conditions
Prepare standard conditions that reflect best practice guidelines (eg IECA standard conditions). Additional conditions can be prepared for high risk sites.
Compliance
26
Development Compliance with Best Practice Standards
Clearly communicate to industry how they are expected to meet Council’s ESC requirements
Provide training opportunities for industry
Provide opportunities for industry to talk to each other and to Council about ESC on an on-going basis to ensure everyone is clear about requirements.
Run-off Water Quality (Mg/L)
Train relevant staff on water quality monitoring procedures and interpretation.
Compliance Inspections and Enforcement
Prepare a Compliance Procedure for Staff that includes how and when to: undertake compliance inspections; use enforcement tools; and keep records of enforcement actions.
This should ensure sites are routinely inspected and Staff have clear direction and authority to use regulatory tools to enforce conditions & EPA.
Develop a site inspection checklist to assist with construction site audits (eg IECA Site Inspection Checklist)
Monitoring Produce conditions that require developers to undertake monitoring within and downstream of their own sites and report results to Council. This information can be used to determine if developers are complying with water quality objectives, and can be used as evidence to enforce conditions or undertake prosecutions if necessary.
Compliance staff qualifications
Provide training and up-skill relevant staff. Councils should define the qualifications required to undertake certain roles.
Managerial Support
Political and Executive Support
Action might include briefing Councillors on the current situation and the findings of the audit. Imagery such as photography from recent site inspection can help visually represent compliant and non-compliant practices. This could be followed-up by regular updates to Council on improvements made to on-ground implementation of ESC measures once the implementation of the Action Plan has commenced.
Resourcing Communicating the current situation and improvements to Council should help to generate support and possibly assist with gaining adequate resources to improve the current situation. The Healthy Waterways ESC Cost Benefit Analysis provides additional data that may also be useful for demonstrating the benefits of ESC to Council (the report can be downloaded from the WbD website).
Awareness
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Awareness within Council (e.g. amongst councillors, executives, development assessment officers, enforcement officers, construction and maintenance staff, etc.), and awareness within the broader community (e.g. local builders, homeowners, developers, contractors).
Develop education tools to:
- assist with distributing information about policy/procedural reforms that have come about as a result of this process.
- emphasise the importance of improving ESC implementation (eg reduced waterway maintenance costs, improved waterway health, improved amenity etc).
Develop a report card on performance and implementation of ESC and distribute report card results to local developers and newspapers.
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Summary & Conclusions
(Council may wish to add text here that summarises the main findings and proposed actions...)
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