AECoW is delighted to provide an update on its consultation meeting which was held on Tuesday 8th December and chaired by Heads of Planning Scotland (HoPS). Stakeholders who attended were the Scottish Government, Energy Consents Unit, several local councils / planning authorities, Association of Local Government Archaeological Officers, the HoPS Development Sub-committee, NatureScot and SEPA. Unfortunately the Marine Scotland, CECA and IEMA representatives were unable to join the meeting, but AECoW will take the outcomes of the meeting back to the IEMA Post Construction Working Group (which we co-chair) to inform its guidance development.
The main items discussed were:
- The definition of an Environmental Clerks of Works vs an Ecological Clerks of Works and who should commission them to maximise their effectiveness
- The definition of ‘independence’, 3rd party / external auditing, specifically in consideration of remuneration and self-regulation
- The definition of ‘ensure’ and who is the legal, responsible party for ‘ensuring’ compliance (ECoW or Contractor)
- The adverse impacts that current environmental monitoring methods can have on individual ECoW carrying out the monitoring work
- The nature, scale and magnitude of environmental non-compliance, and associated environmental impacts during construction: knowns and unknowns
- Current barriers in the development, and construction, industries, including cultures, which inhibit achieving environmental compliance
- The nature of D&B (and other) contracts vs environmental regulation; the lack of synergy and conflicting interests / competing priorities that adversely affect achievement of compliance
- Potential regulatory, and industry, reform which may be required to drive up environmental standards and compliance.
We recognise that we are making great progress with regulators and stakeholders in Scotland, and less so in other areas of the UK, so our strategy is to continue working with the above to groups, and stakeholders, and use the outputs from them to bring stakeholders from across the UK into the discussions during the next phase of consultation. The final phase of consultation will involve engagement with all UK governments and regulators. As part of this process, we are also considering international research, to better understand how environmental monitoring is managed, and regulated, in other countries, to learn through sharing good practice.
If you know any regulators, or stakeholders, who would be interested in this development work, or if you are interested in this, please get in touch at firstname.lastname@example.org.