An Audit Tool to Help Improve the Effectiveness of Erosion and
Sediment Control Programs in Local Government Agencies
(version 2)
16 May 2013
Integrated Urban Water Scientific Expert Panel, Healthy Waterways
Purpose
This document presents a simple auditing tool that can be used within local government authorities
(LGAs) to assess the adequacy of internal programs (management systems) to manage erosion and
sediment control (ESC) in order to protect the health of local and regional waterways, as well as
maintain stormwater infrastructure.
Ideally, this tool would be used as part of an internal audit requested by the organisation’s CEO or
Mayor. In most circumstances the audit would identify opportunities to improve the organisation’s
ESC program, which should lead to improvements in the way that ESC is managed on local building
sites, development sites as well as Council's own construction activities.
Sources of assistance
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




The Water by Design program, Healthy Waterways.
ESC specialists within the Department of Environment and Heritage Protection.
Consultants who are ‘Certified Professionals in Erosion and Sediment Control’ (see
http://www.austieca.com.au/cpesc).
The Integrated Urban Water Scientific Expert Panel (Healthy Waterways).
ESC specialists in Councils with considerable experience with this issue (e.g. Brisbane,
Sunshine Coast).
Technical guidelines, e.g. “Best Practice Erosion and Sediment Control” (IECA, 2008);
“Procedural Guide: Compliance Notes: Standard Work Method for the Assessment of the
Lawfulness of Releases to Waters from Construction Sites – South-East Queensland”
(Department of Environment and Resource Management, undated).
Standard conditions for ESC. These are currently being developed by the Water by Design
program in consultation with local government practitioners in SEQ.
Prepared by: The Integrated Urban Water SEP (Healthy Waterways), with input from:

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Dr André Taylor (SEP Chair).
Mr Ben Starr (O2 Environment and Engineering; a CPESC).
Mr Steve Tracey (Healthy Waterways / Sunshine Coast Regional Council).
Mr Leon Rowlands (SEP and Sunshine Coast Regional Council).
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The ESC Audit Tool
The table / tool below summarises the features of a ‘best practice’ ESC program within a local government authority. These features reflect relevant research and
the views of experienced ESC practitioners. An auditor would use the tool as a checklist to assess whether each feature is present and strong within the LGA, and
if not, identify some actions to strengthen relevant features.
Features of a best practice
ESC program
1. Political and executive
support
Questions to consider
a.
b.
c.
Current level of
performance
Recommended actions to
improve performance
Very poor   very good
Strengths /
Weaknesses of the
current program
(Auditor to complete this
column)
(Auditor to complete this
column)
(Auditor to complete this
column)
Is there strong support for establishing a high standard of ESC
across the city / shire at political and executive levels in
Council?
Do staff ‘at the coalface’ feel supported on this issue (e.g. to
insist upon a high standard of ESC during development
assessment, enforcement, construction or maintenance
activities)?
Are ‘ESC champions’ that emerge as leaders within Council
encouraged and supported?
    
Does Council have a clearly defined policy and a set of
planning controls to ensure that all significant land disturbing
activities must take measures to assess and manage ESC?
Does Council have clear standards that outline the required
level of erosion, sediment and drainage controls to be
implemented by developments, or do they simply refer to the
requirements of a recognised guideline (i.e. the IECA’s 2008
“Best Practice Erosion and Sediment Control” guidelines)?
Standards are preferred.
Are ESC plans required to be developed, assessed and
approved / certified by suitably qualified professionals as part of
the development assessment system?
Is the responsibility for the implementation and maintenance of
these ESC plans clear?
Does Council have adequate ESC expertise in its development
assessment team? If not, do they draw on external parties to
access this expertise? [Note: Some Councils choose not to
“assess” ESC Plans. In this situation, Council should ensure
that ESC Plans have been certified by a suitably qualified
professional (e.g. CPESC) as being prepared in accordance
with Council’s defined standards.]
    
[please tick one]
2. Policy, planning controls
and development assessment
a) Policy and planning controls
to address ESC through the
development assessment and
building approval process.
a.
b.
c.
d.
e.
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Features of a best practice
ESC program
Questions to consider
Current level of
performance
Very poor   very good
f.
g.
h.
i.
j.
b) Policy to address Council’s
own ESC performance during
construction and maintenance
activities.
a.
b.
c.
d.
e.
3. Compliance & Enforcement
a.
Strengths /
Weaknesses of the
current program
Recommended actions to
improve performance
Does Council have an erosion risk assessment process in place
to identify ‘high-risk projects’ that require a high level of ESC
planning and management?
Does Council have a mechanism to require ‘high risk projects’
to submit a ‘concept ESC plan’ at an early stage in the
development process (e.g. reconfiguring a lot)?
Does Council require developers to submit a ‘detailed ESC
Plan’ at the operational work space for all developments over
2,500m2 (State Planning Policy for Healthy Waters trigger
level)?
Does Council exercise its ability to critically review, accept or
refuse concept or detailed ESC plans? [Note the comment
above about some Councils not approving these plans. In this
situation Council should ensure plans have been certified by a
suitably qualified professional.]
Does Council issue conditions relating to ESC at the
operational works approval stage that are consistent with, and
supported by, technical guidelines such as: the “Best Practice
Erosion and Sediment Control” guidelines (IECA, 2008); and
the “Standard Work Method for the Assessment of the
Lawfulness of Releases to Waters from Construction Sites –
South-East Queensland” (DERM, undated)? [Note that a single
set of standard conditions for ESC is being prepared for SEQ at
present by Healthy Waterways in consultation with LGAs.]
Are policies in place to ensure that ESC standards on Council’s
own building, construction and maintenance works represents
best practice and set a positive example for local stakeholders?
Does Council have a risk assessment mechanism to identify
‘high risk’ works, and ensure that such works have an ESC plan
that has been prepared by a suitably qualified professional (i.e.
a Certified Professional in ESC)?
Does Council develop concept plans for those high risk
developments prior to letting a project for tender?
Is the responsibility for managing ESC on Council projects clear
(i.e. at the site, project manager and executive level)?
Are meaningful incentives / disincentives in place to ensure
Council’s construction and maintenance staff set a good
example with respect to ESC?
    
Does Council employ or engage suitably qualified and
experienced staff (e.g. a Certified Professional in ESC) to
routinely inspect construction / building sites and enforce ESC
compliance on the ground?
    
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Features of a best practice
ESC program
Questions to consider
Current level of
performance
Very poor   very good
b.
c.
d.
e.
f.
4. Management systems
    
a.
Is sufficient funding made available to staff to adequately
assess plans (where necessary), routinely inspect high risk
sites, and apply regulatory / enforcement tools where
necessary?
    
a.
Does Council have initiatives in place to ensure these people
have a good understanding of the significance of ESC as a
threat to healthy waterways in SEQ, what can be done to
manage it, and the relative benefits vs costs of ESC?
    
b.
c.
d.
5. Resourcing
Recommended actions to
improve performance
Does Council strategically use enforcement tools such as onthe-spot fines, stop work notices and prosecutions for clear
breaches of ESC development conditions or regulations?
Does Council routinely and frequently inspect high-risk
construction / development sites to assess legislative
compliance, or require developers to engage suitably qualified
third parties (e.g. a Certified Professional in ESC) to inspect
and report to Council on compliance status?
Does Council have in place mechanisms to promptly investigate
ESC compliance following a complaint?
Does Council have a track record of successfully enforcing ESC
conditions and regulations, as well as procedures, systems and
cultures that support successful enforcement action?
Does Council work with the State government to ensure that
local and state government ESC enforcement officers apply
similar standards?
Does Council have a well-maintained ‘environmental
management system’ that includes procedures to ensure risks
associated with ESC are identified and managed?
Is there an internal system to check that ESC management is of
a high standard and is maintained at this level (e.g. annual
audits using this protocol)?
Are systems in place to ensure that the standard of ESC
management remains high regardless of staff turnover (e.g.
induction systems, detailed role descriptions, ESC-related
procedures)?
Are mechanisms in place to ensure that key staff are
accountable for managing ESC as part of their role (including
executive staff)?
a.
Strengths /
Weaknesses of the
current program
6. Awareness of ESC
a) Awareness within Council
(e.g. amongst councillors,
executives, development
assessment officers,
enforcement officers,
construction and maintenance
staff, etc.).
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Features of a best practice
ESC program
Questions to consider
Current level of
performance
Very poor   very good
b) Awareness within the broader
community (e.g. local builders,
homeowners, developers,
contractors).
a.
Does Council have programs and products in place to help
raise awareness of ESC within the broader community,
especially within the local development, building and
construction industry?
    
7. Specialist training
a.
Do staff in the following Council areas receive specialist training
in ESC: development assessment; enforcement / inspection;
design (ESC plan preparation), construction and maintenance?
Is there at least one staff member in Council who has advanced
ESC training (i.e. a Certified Professional in ESC)?
Are ESC enforcement officers suitably trained in common ESC
management strategies as well as enforcement procedures?
    
Is a system in place to regularly conduct ESC audits across the
city / shire to measure typical compliance rates and track ESC
performance over time (e.g. every 1 to 2 years)?
Is a system in place to regularly conduct ESC audits across
Council’s own construction / maintenance projects to measure
typical compliance rates and track ESC performance over time?
Do these audits lead to improved action (e.g. a focus on
improving the management of ESC in a particular segment of
the building industry)?
    
Is there a mechanism within Council to keep up-to-date with
new ESC technology and disseminate new knowledge
throughout the organisation?
Does Council trial new technology (e.g. on its construction sites
or in partnership with local developers / builders)?
Do Council officers liaise with people playing similar roles in
other organisations to improve ESC knowledge and practice in
the region?
    
Do incentives exist within the organisation for staff to put in
extra effort to manage ESC (e.g. awards, recognition or reward
systems)?
Are there any incentives offered to builders / developers who
have a track-record of high ESC performance (e.g. fast tracked
development approvals, public recognition, or awards)?
    
b.
c.
8. Audits to track
performance over time
a.
b.
c.
9. Technology and innovation
a.
b.
c.
10. Incentives
b.
c.
Strengths /
Weaknesses of the
current program
Recommended actions to
improve performance
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