To support the SuRF-UK Framework document, the SuRF-UK Steering Group has prepared some answers to Frequently Asked Questions that they have received since the launch of the framework. They hope that these answers will provide greater clarity on the main issues and will encourage more people to use the framework document.
Frequently Asked Questions
1. Why should you consider sustainability factors when assessing soil and groundwater remediation?
Numerous legislative and corporate policies require a commitment to sustainable development. Including sustainability considerations into soil and groundwater management decisions is one way for the remediation industry to transparently contribute to those goals. It is now considered good practice. Your overall design may be better and you will have demonstrated that the remediation has been carried out in a sustainable way, which may be required by client, regulatory, planning or other interests.
2. Can we use Sustainable Remediation in the UK?
Yes! Regulations and guidance are already written in a way to embrace sustainable development concepts that can be applied to remediation.
3. What is the point of Sustainable Remediation?
- To mitigate unacceptable risks to human health and the environment in a manner that derives the greatest overall (sustainability) benefit,
- To demonstrate compliance with public and corporate sustainable development policies and commitments
- To make discussions and communication with stakeholders easier
- Makes planning applications stronger
- To introduce a balanced way to deal with economic, social and environmental considerations
4. Isn’t this a lot more work / cost?
Not really! Most sustainability assessments are likely to be straightforward, and will be a simple modification of the familiar risk assessment/options appraisal/remediation process.
5. How does the SuRF-UK framework relate to CLR 11?
The SuRF-UK framework document supplements the options appraisal process identified in CLR 11. They are not two different processes. CLR 11 is an overarching framework and SuRF-UK framework provides a finer level of detail to assist in the decision process of a sustainable remedial option.
Extracted and adapted from: Model Procedures for the Management of Land Contamination (CLR11). 2004. Defra and Environment Agency.
6. Can the SuRF-UK framework be used on large projects and small projects?
Yes, it has been designed with a tiered approach like CLR 11, which allows flexibility depending on the size of project.
7. Is it cost effective to undertake a sustainability assessment on a small redevelopment project?
Absolutely. It is important that sustainability is considered on all sizes of project, whether large or small. The sustainability appraisal must however be proportionate to the size of the project which is why a simple qualitative assessment may be all that is needed and is probably no more than you typically already do when redeveloping a site. The difference is that you are following a clear and accepted framework and recording the decisions that you have made to demonstrate transparency.
8. Should you carry out a sensitivity analysis when undertaking a sustainability assessment?
Yes it is good practice to do this and will demonstrate the decisions that you have made are robust and defensible.
9. What is the benefit of having a standardised indicator sheet as there are many indicators that people can use documented throughout literature. Do you have to use the SuRF-UK indicators?
Having a standard approach to indicators will allow consistency and transparency in approach. SuRF-UK has provided a table of overarching categories for the indicators that you might select. Ensuring that, as far as is appropriate, you have selected indicators across these categories will help ensure a holistic sustainability appraisal and a common approach. The sustainability indicator category table was created after an extensive literature review. It is not compulsory to use but hopefully is seen as a useful checklist when undertaking a sustainability assessment. If there is an agreed cross industry approach then people will know the basis upon how decisions have been made.
10. The framework discusses stakeholder engagement. Why involve stakeholders?
A key part of assessing sustainability is engagement with the stakeholders who will be the users of the assessment (for example, planners, communities, or who can affect, or are significantly affected by the decision.). This is an integral part of sustainable development. It is also a useful practical exercise. As sustainability assessment is essentially a subjective process, early engagement and transparency in assessment approach will greatly improve the chances of achieving a common understanding between all stakeholders, and hence the chances of an acceptable and durable decision based on sustainability.
11. How do you select your stakeholders?
The stakeholders at the centre of decision making are generally the project team, comprising the client for the project and/or the site owner, the service provider, the regulator(s) (including their advisors) and planners, and perhaps groups who might be affected by the Construction Design and Management of the project.
However, other stakeholders can be influential, such as those who might use the site (workers, possibly unions, and other visitors); those who have a financial involvement in the site or the site’s ownership (e.g. banks, founders, lenders, insurers); the site’s neighbours (adjacent owners and tenants, local communities and councils); and particularly for more complicated problems other technical specialists, researchers, non-governmental organisations (NGOs) and pressure groups. In general, the more complex the site (both from a technical point of view and in the context of its local circumstances) the greater will be the influence of these other stakeholders. You may limit the stakeholder numbers to make it workable and effective. It is also important to identify temporary as opposed to permanent effects to stakeholders when undertaking your sustainability assessment. The planning process will often allow engagement with a wide selection of stakeholders so it is important not to duplicate.
12. When selecting stakeholders do you consider intergenerational aspects?
Yes this is an important aspect to consider as the decisions that you make today will impact future generations. This is addressed within the sustainability indicator categories provided by SuRF-UK.
13. How do you communicate technical issues with “lay/non technical” stakeholders?
It is important to use appropriate language when dealing with non technical stakeholders who may not understand the technical terms or remediation options considered other than in so far as it directly affects them. The SuRF-UK framework will help show how decisions are reached following a robust and defensible process. It is also very important to engage with your stakeholders early on to identify which indicators are most important to the different stakeholders and to use this understanding to identify appropriate communication techniques, such as plain English summaries and visual presentation tools.
14. What are Boundaries?
The term “Boundaries” describes the practical limits to the sustainability assessment process that allow a meaningful decision to be made. For example, what is the problem to be solved? What are the key factors that you want to evaluate? When you are considering different remedial technologies ensure that you are aware of the parameters that you are working in i.e. what time frame is acceptable? Are there legal or contractual commitments that are not negotiable? Are you including the sustainability of manufacturing the machinery that is used to undertake the remediation, or is it restricted to the transportation and use of the equipment? What timescales are the benefits/impacts being measured over.
15. One of the indicators is carbon dioxide emissions. How do you ensure that all carbon calculating tools available in the market place are calculating carbon the same way?
You cannot be sure that each tool is measuring carbon impacts the same way, however if you document your methodology then there will be transparency in your approach.
16. How can I use sustainability as a practical tool in the design and development of remediation options before a final options appraisal?
In practice the development and appraisal of options will be an iterative process, where comparisons between options and opportunities gradually lead to a better set of available options. Two broad activities of sustainability assessment can be envisaged: development work for designing options and evaluating the options consequently developed. The sustainability assessment steps that will be followed will be similar for both applications although with varying level of detail.
- Developing options: It is likely that, where sustainability is a factor in the design of options, development will proceed in an iterative way, with sustainability assessment being used to help evaluate successive enhancements. In many cases, pragmatic considerations will mean that this work is executed by the project team and a perhaps narrow group of stakeholders. The output of this work will likely be a set of options to be presented to a wider decision-making community.
- Evaluating options: this is where sustainability assessment is used as a consideration in deciding between available options for a project design (Stage A) or remediation management plan (Stage B). In this circumstance it is preferable to use a participatory approach.
17. How far does one need to go before you undertake a quantitative assessment?
In many situations you would not wish to jump straight into a quantitative assessment as it would be too costly, time and data hungry and not always justified. For simple and small projects a qualitative appraisal may be adequate.
18. What is the value of using Cost Benefit Analysis (CBA) and Multi Criteria Analysis (MCA) in a sustainability assessment?
These tools should typically only be used once a qualitative assessment has been undertaken and you have engaged with stakeholders to reduce the potential options available. A CBA or MCA can be useful when a site is complex and there are a number of different options to consider and can help to inform and decide on the best remedial strategy to be taken, and also where there are areas of disagreement between stakeholders.
19. How can I convince my client that there are benefits of doing a sustainability assessment when remediating a site?
Clients often want to demonstrate the Corporate Social Responsibility (CSR) credentials of their business to comply with their own corporate policies on sustainable development, and to be seen to be acting responsibly. By carrying out a sustainability assessment following a recognised framework, will ensure that your client is helping to meet their CSR credentials and directly contributing to sustainable development within the scope of their remediation programme. It should also maximise the value generated by investment in remediation, and may have reputational benefits.
20. Does the SuRF-UK framework give a mechanism to allow less sustainable decisions to be made owing to over arching business or regulatory constraints?
Yes it does. Less sustainable options can be selected but there is a process to document why this route has been taken. The aim of the SuRF-UK framework is to help set up the drivers in the first place that less sustainable decisions are not taken. If drivers cannot be changed then decisions that are made need to be documented. The framework is voluntary and it is there for people to use to help develop their sustainability thinking when undertaking soil and groundwater remediation.
21. My project includes explicit sustainability objectives. How does this fit into the SuRF-UK framework?
In some cases project stakeholders may agree amongst themselves to include specific sustainability objectives in a project, as well as risk management objectives. Here are some examples:
- Remediation work is part of a larger redevelopment and construction project which includes targets on materials re-use and waste minimisation;
- An operational site remediation may be required to comply with corporate policies relating to carbon intensity and water use;
- A community based restoration project might include a broad range of goals relating to local area improvement and community benefits.
These explicit sustainability objectives can both be included with a SuRF-UK sustainability assessment and monitored separately. The advantage of this is that not only can decision-
making take into account specific project sustainability and risk management objectives; but it can also consider the wider benefits and impacts that accrue to different ways of reaching these goals. This is important because few projects will be able to set a comprehensive set of explicit project targets across the entire range of possible benefits and impacts. This combined approach improves efficiency by allowing decision makers to focus on a few key sustainability parameters; and also be able to consider the sustainability of different options in a holistic way as well. The parameters linked to sustainability objectives would simply be included in the overall indicator set developed across the SuRF-UK headline categories as part of the overall assessment. Bear in mind it is possible that a remediation method that performs best across a few specific parameters (e.g. carbon footprint) may not necessarily be the most sustainable when a broader holistic set of sustainability indicators are considered using the SuRF-UK framework.