Environmental assessments should be conducted by a suitably qualified environmental consultant. In Victoria, a suitably qualified environmental consultant is a professional with significant technical expertise and experience in their specific field (e.g. contaminated land). Other states may have specific requirements (such as CEnvP certification).
Planning Permit Conditions and RFIs often call for the land to be assessed by a suitably qualified environmental consultant.
Suitably qualified environmental consultants demonstrate an ongoing commitment to professional engagement and development. They are usually members of professional organisations such as ALGA, EIANZ, or ACLCA.
The publication National Environment Protection (Assessment of Site Contamination) Measure (ASC NEPM) Schedule B9, discusses the characteristics of contaminated land professionals, auditors, and third-party reviewers.
Further information is also available in publication Planning Practice Note 30 – Potentially Contaminated Land (July 2021) and EPA Victoria website.
Ensure your consultant is suitably qualified to assess your site.
In Victoria, waste soil is classified by a suitably qualified environmental consultant in accordance with EPA Victoria publication 1828.3 – Waste disposal categories: characteristics and thresholds (September 2024). It requires a consultant to sample the soil in discrete domains and can be conducted in-situ, or in a stockpile.
Often this work is conducted during an environmental site assessment but can also be conducted on request prior to earthworks or on an ad-hoc basis (a waste stockpile). The consultant will sample the soil, have it tested at a laboratory, interpret the results compared to EPA Victoria guidelines, and write a classification letter for the material. The waste classification letter can be used to dispose of the material at a lawful place (in conjunction with waste transport certificates if required).
The costs associated with disposal of soil can vary widely depending in the outcome of the classification exercise (Fill Material, Category B, C, or D). The highest category of soil waste is Category A material. It may not be disposed of at a landfill, and must be treated prior to disposal.
Often there are overlooked opportunities to reduce a waste classification (and subsequent disposal cost) by remediating material onsite. It is worth talking to your consultant about remediation options if time and space onsite permit. Soil remediation and reclassification may provide significant cost savings and can carry a higher sustainability value if the material can be retained onsite.
Ensure your soil is properly documented and classified prior to removal from site.
The time it takes to assess potentially contaminated land in Victoria depends on various factors such as project aims, land use, the size of the site, ground conditions, and the nature of contamination (if present).
Simple waste soil classification can be conducted very quickly (1-2 weeks), similarly with Preliminary Site Investigation/Phase 1 assessment that might take up to 2-4 weeks to turn around a report.
More complex investigations (Environmental Site Assessment, Detailed Site Investigation) can take longer to plan and execute, and the time it takes to conduct the assessment is subject to various factors such as contractor availability, the quantum of sampling required, site access, further investigation around subsurface infrastructure, the amount of remediation if soil or groundwater is sufficiently impacted, regulatory oversight, or the requirements of closing out an Environmental Audit (under a separate third-party Environmental Auditor).
Early engagement of an environmental consultant can often mitigate potential project delays.
In Victoria, an Environmental Audit Overlay (EAO) indicates that an environmental audit or Preliminary Risk Screen Assessment (PRSA) of the land is required prior to that land being used for sensitive use. It indicates that the site may have potential for contamination from historical activities (such as industrial use). The EAO will be indicated on planning information, such as a Planning Property Report, and can be viewed online at Victoria Unearthed.
Completing a PRSA involves an EPA appointed Environmental Auditor issuing a PRSA for the site following review of known information on the site (such as a Preliminary Site Investigation). The PRSA will state whether an Environmental Audit is required. Completing an Environmental Audit involves engaging a suitably qualified environmental consultant to conduct a Detailed Site Investigation of the site, and engaging an EPA Victoria approved Environmental Auditor to conduct an Audit of the DSI as it progresses. An Environmental Audit Statement will not be issued by an Environmental Auditor until all actions have been taken (appropriate assessment, remediation, validation) to confirm the site is suitable for it’s proposed use.
Early engagement of a suitably qualified environmental consultant and environmental auditor is recommended to address an EAO to avoid possible delays to your project.
A Preliminary Site Investigation (PSI), sometimes known as a Phase 1 Assessment, is the first step in identifying if a piece of land has potential for contamination from current or historical uses. It may also identify potential for contamination from offsite activities. It will consider the characteristics of the site, review of the history of the site, and review of environmental registers. It will usually also involve a site inspection to review any observable indicators of potential for contamination.
The PSI attempts to identify any potentially contaminating activities (or absence of) that have occurred and consider potential sources, pathways, and receptors of potential contamination (preliminary conceptual site model).
A PSI should be conducted by a suitably qualified environmental consultant.
Often PSIs are required as a condition of a Planning Permit Application to determine if further action is required prior to development, but may also be used by proponents as an initial step in conducting their due-diligence on a site, or as the first stage in a Detailed Site Investigation (DSI).