Model Procedures for Management of Land Contamination - Environment Agency consultation

21 November, 2003

The Environment Agency issued a draft of the above for consultation and the HBF has responded.

The proposed document is long and not very 'user-friendly'

There is virtually no reference to geotechnical issues whcih we see as a major omission and there is little guidance on practical and realistic how to do solutions.

It appears that no account has been taken of the day to day commercial realities in regard to the short timeframes associated with land purchase. It is also unclear who will be responsible for approving/agreeing the remediation strategies and for confirming eventual compliance. One positive aspect is the schedule of informative references.

For the full text of the HBF response please follow this link.