In the second of two very different articles focusing
on the Part IIA contaminated land regime, Dr Jo Gilman takes
a practical look at how the Contaminated Land Risk Analyst
system (CLARA) can help local authorities prioritise sites
Ask any local authority how they are implementing their Part IIA
responsibilities and you will get a different answer. By now, all
local authorities in Britain will have written and had approved
their contaminated land strategy document which should set out how
they plan to implement Part IIA in their own area. For many local
authorities this will be a very broad set of statements, which stops
far short of addressing the actual procedures that will be used
to tackle the issue. How far local authorities have moved on from
this point varies considerably - with some surging ahead while others
watch the dust gather on the original documentation feeling unable,
for one reason or another, to take the first steps in the practical
implementation process.
The progress of any particular local authority seems to depend
on a whole multitude of factors, including available funds, availability
of data, format of data, type of software (if any), and perhaps
most importantly staffing levels. There is a wide variation in the
ability of different local authorities to provide these basic tools
to those working with Part IIA issues, and this has left some local
authorities feeling unsure as to how they should move into the implementation
phase of this work.
Although funding was made available to help local authorities implement
Part IIA, it was not "ring fenced", and as a result some
seem to be working without any, or perhaps minimal additional funding
for required purchases. Environmental health departments need an
adequate toolkit to implement Part IIA, comprising of:
personnel;
data - both modern day and historical;
a system for managing the data; and
a system for implementing Part IIA in line with the contaminated
land strategy document.
PERSONNEL
This is the key first requirement for Part IIA implementation.
Discussions have shown that some departments that have been working
towards Part IIA have been stopped in their tracks if additional
responsibilities have been placed on their staff, or indeed if staff
have moved their place of employment. Some local authorities have
whole teams of people dealing with contaminated land, while others
can release only part of an employee's time for Part IIA. As far
as the implementation of the legislation is concerned, it is the
completion of work relative to the objectives in the contaminated
land strategy document that is important, and as long as some progress
- however slow - is being made, then this is better than none at
all.
Some initial strategies were written up within incredibly short
time periods for Part IIA implementation, which may well have proved
too challenging when it came down to actually doing the work. Others
however, have stated that it will take five years or more to implement
this legislation subject to annual review. Although this gives a
lot of opportunity for procrastination, it also provides local authorities
with limited resources a realistic goal to aim for when practically
undertaking the required tasks.
DATA
The data requirement for successful implementation is fairly substantial.
Not only is there a requirement to know the location of modern day
land-use in order to identify those sensitive to historical contamination,
but the whole substance of Part IIA is to identify and locate areas
that have been under historical industrial use of some sort which
may have caused contamination of the land in the past. Current environmental
data detailing geology and water resources, for example, are also
required in order to assess the likelihood of contamination moving
away from the original industrial site via so called "contamination
pathways" affecting modern day sites at more remote locations.
To assist environmental health practitioners with Part IIA implementation,
the following data will be helpful:
Historical maps:
Information about the industrial history within a local authority
area is the starting point for implementing Part IIA. The local
authority may well hold archive copies of historic maps charting
the development of the borough or district, and if not held
at this level, there may well be rich archives at county level.
If such archives do not exist, then this mapping can still be
purchased, the most commonly quoted supplier being Landmark.
The cost will vary according to the size of the area under consideration
and could be substantial. In some cases discounts have been
offered when different local authorities work together and arrange
a bulk purchase. Mapping can be purchased in different digital
formats suitable for specific GIS and other electronic mapping
systems. Some local authorities are making use of student labour
to create digital datasets from existing paper mapping which
has proved a cost-effective alternative.
Aerial photography:
This is a useful resource to have whether in paper or digital
format. However, purchase from external suppliers is likely
to carry a considerable cost if the photography is fairly recent.
Aerial photographs allow the assessment of features such as
slopes (if viewed stereoscopically), land use and ground cover
(for example, to assess the integrity of a landfill cap) without
having to visit the site.
Geological maps:
Geological information is key to understanding the groundwater
situation for a site. Highly permeable geology will allow water
to pass through it, whereas an impermeable rock will not. This
is important when considering the existence of contamination
pathways underneath potentially contaminated sites. This data
may already exist at the local authority. If not, it can be
purchased from the British Geological Survey (BGS).
Environment Agency data:
This is available in digital format from the EA on CD. It contains
many data sets, including water management boundaries, licensed
waste disposal sites and licensed water abstractions, which are
sensitive receptors for contamination.
English Nature data: This is freely downloadable off the website
(www.english-nature.co.uk)
in formats compatible with Microstation (.dgn), MapInfo GIS,
and .DXF (generic). There are two options for data download.
One is 100km2 (comprising SSSI, special areas of conservation,
special protection areas, Ramsar sites, ancient woodlands, and
national nature reserves). The other is all England datasets
(comprising the same data except for the exclusion of ancient
woodlands and the inclusion of natural areas, and character
areas).
As the above list, which is by no means exhaustive, shows the data
requirements are considerable. The environmental health department's
financial position, and the software investment that it is faced
with will have a significant impact on the quantity and format of
data that can be utilised. The data could all be digital and integrated
into a inter-departmental GIS, or it could be mainly paper mapping
which can either be used in this format, or could be digitised for
a local GIS using students or volunteer workers. The importance
of investing in good digitising hardware and software should not
be underestimated.
A SYSTEM FOR MANAGING DATA
While it may seem that a GIS software system has to be used for
Part IIA, it can be approached without one. The decision has to
be made between making the financial investment - in order to make
use of such technology - as opposed to working outside an electronic
system and accepting the considerably longer time-investment that
will be necessary to approach this task manually. Some of the more
affluent local authority departments are considering bespoke software
systems from external suppliers, which are designed to integrate
into existing software and database systems whereas others are trying
to work out how simple spreadsheets can be put to good use.
Once the decision on the type of system to manage Part IIA has
been made, if GIS is to be used, there are many different systems
to choose from. Some of the well-known systems such as ESRI's, ArcView
and MapInfo may cost slightly more than others. However, they bring
with them advantages, such as more compatible partner extension
packages, some of which are specifically designed to help with the
implementation of Part IIA and can also be incorporated into the
strategy. Cheaper, yet less compatible GIS systems can be implemented,
but will probably remain as stand alone systems that are used in
single departments.
Besides the purchase of GIS software, there is also the issue of
whether the local authority has been able to recruit and retain
technical staff with the knowledge and training to utilise the systems
to their full advantage. This should not be ignored if the full
benefit of GIS is to be gained both for Part IIA and for subsequent
projects.
A SYSTEM FOR IMPLEMENTING PART IIA
The implications of how this is done in line with the contaminated
land strategy document is not often fully appreciated until the
job has been under way for some time, and some of the difficulties
and prioritisation issues are being dealt with. When prioritising
the risk associated with the identified potential source sites,
the most important thing is to treat them all in the same way. If
certain data sets are incomplete, it is better not to use that information
at all. If it is applied to some sites and not others, the assessment
of risk across all the sites will not then be comparable. If certain
data is not considered for all sites, at least the integrity of
the relative risk defined for each site is maintained.
Unfortunately, regardless of the resources available to each environmental
health department, the size of the job facing the majority of authorities
is fairly similar. Admittedly, some large unitary authorities with
a rich industrial history do have a greater than average land contamination
problem to tackle, while some smaller authorities with many greenfield
areas, could have a relatively small number of potentially contaminated
sites to deal with. It would, however, be fair to say that managing
Part IIA responsibilities is acknowledged as a significant task
for the majority of authorities who have actually sat down to assess
exactly what it really involves.
Many different approaches are being used to assess the level of
risk that historical contaminative land use poses to modern day
receptor sites and these tend to relate to the issues already discussed.
In the case of local authorities that have adopted the Contaminated
Land Risk Analyst (CLARA) model, the amount of automation adopted
within ArcView GIS, and the amount of digital as opposed to paper-based
data to use, is for the local authority to decide.
CASE STUDY
Darlington BC, which uses the CLARA system, is a fairly typical
local authority, which has employed a single staff member to take
responsibility for risk screening all sites. According to Tracy
Hilton, technical officer at Darlington BC, a data trawl and initial
investigation revealed that Darlington has over 2,000 sites that
require both screening for pollutant linkages and prioritisation
for inspection. The council decided that an efficient way to handle
the sites would be to place them into categories based on their
nearest identifiable receptor areas, ie areas of land with a potentially
contaminative source and having a relevant receptor nearby such
as residential property with gardens, controlled waters, ecological
systems etc. By doing this, says Ms Hilton, the source areas are
then ready for risk assessment using a system of priority based
upon the sensitivity of its nearest receptor. The risk screening
process involves the following: defining the receptor themes; screen
digitising the source areas using GIS; loading the source themes
into CLARA; and performing systematic risk assessments.
As Ms Hilton explains, the risk assessment software chosen must
be able to handle this approach and provide robust risk screening.
It is also important that it has a scoring system, which is sensitive
enough to generate a discernible final output score without showing
the clustering of similarly ranked sites. "CLARA has shown
to provide this because the default land use types and scores supplied
with the software can be customised," says Ms Hilton. "We
wanted to test this by adding categories of land use adapted from
the Department of Environment industry profiles which were assigned
a score of between 1-10, dependant on the potential seriousness
of the hazard associated with the type of industry." The council
also wanted to trial the risk assessment software so as to avoid
making a purchase and finding out several months later that the
software could not meet its specific needs.
According to Ms Hilton, CLARA uses a thorough questionnaire dialogue,
which provides a robust and comprehensive risk-screening tool and
takes account of local development, groundwater, surface water,
air quality and human health. The programme operates at the GIS
interface, which means that historical and modern data sets can
be used for analysing particular sites. An authority can, for example,
load a data set of landfill information straight into CLARA and
commence risk assessment. "The programme is also excellent
for handling data-in-the-making, for example, the source data sets
digitised in-house," says Ms Hilton. "If a risk assessment
is required for a particular site, it can be loaded into the relevant
theme in CLARA and the risk assessment process undertaken while
simultaneously adding new information to that theme as it unfolds.
This is because CLARA updates the scores and rankings of each site
as changes and additions are made."
As Darlington BC has found, CLARA also has an in-built reporting
facility, which allows the efficient storage of site information
and the option to send secure reports to relevant stakeholders.
The council's experience in using CLARA as a risk assessment programme
shows that a methodical approach, making best use of available resources,
can be used to implement a thorough and defensible approach to the
Part IIA legislation. Hopefully, Darlington BC's experience will
give some comfort to other local authorities that feel that they
have neither the budget nor the personnel to deal with their Part
IIA responsibilities properly.
Dr Jo Gilman is senior consultant with Conestoga-Rovers
& Associates (UK) Ltd.