Soil Erosion & Sediment Control
Internal Management Systems Review
Report Template & Action Plan
Introduction
The following document is a template that can be used by Councils undertaking an ESC Internal Management
Systems Review. This document can be populated as the Council follows the Steps outlined in the ESC Internal
Management Systems Review - Step-by-Step Guideline (download from Water by Design Webpage). Each Step
will prompt Council to collect relevant data to input into this template so that once completed it will provide a
summary of the current situation with a plan for action. Results in this report should ideally be retained so it
can be used as a baseline for comparison with any future investigations to demonstrate the progress and
success of implemented changes. Council may choose to edit any part of this document to reflect local issues
and relevance. For example, a blurb could be included on this front page that covers the local situation and the
background that led to this review, along with Council’s title and logo etc. Councils may also like to change or
add its own parameters to the data collection tables. Please note this is a guide only, and the Steps are purely
suggestions. As each Council will have its own issues and priorities the focus should be on what is locally
relevant and important.
If you have any questions regarding the use of this document please contact Water by Design which is a
program of Healthy Waterways Ltd: hwwinfo@healthywaterways.org or telephone (07) 3177 9100.
Step 1: Gain Managerial Support &
Build an Internal Review Team (IRT)
Step 2: Rapid Desk Top Assessment
Step 3: ESC Policy Review
Step 4: ESC Plan Review
Step 5: ESC Compliance Process Review
Step 6: Staff Surveys
Step 7: ESC Score Card
Step 8: Develop an Action Plan
Step 9: Annual Review
Table of Contents
Introduction ............................................................................................................................................................ 1
Table of Contents .................................................................................................................................................... 2
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT) .............................................................. 3
Internal Review Team ......................................................................................................................................... 3
Managerial Support............................................................................................................................................. 3
Step 2: Rapid Desk Top Assessment ....................................................................................................................... 4
Step 3: ESC Policy Review........................................................................................................................................ 5
ESC Policy & Guideline Review ............................................................................................................................ 5
Training and Education........................................................................................................................................ 6
Step 4: ESC Plan Review .......................................................................................................................................... 7
Step 5: ESC Compliance Process Review ................................................................................................................. 8
ESC Site Inspection Results.................................................................................................................................. 8
ESC Site Inspection Photographs......................................................................................................................... 8
Desk-Top Compliance Records Review ............................................................................................................... 9
Step 6: Staff Survey ............................................................................................................................................... 10
Instructions:....................................................................................................................................................... 10
Development Assessment Staff Survey Template ............................................................................................ 11
Development Assessment Staff Survey Results ................................................................................................ 14
Compliance Officers Survey Template .............................................................................................................. 15
Development Assessment Staff Survey Results ................................................................................................ 18
Step 7: ESC Internal Management Systems Score Card for Councils .................................................................... 19
Step 8: ESC Action Plan ......................................................................................................................................... 26
Summary & Conclusions ....................................................................................................................................... 29
2
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT)
Internal Review Team
An internal review team was established on (insert date) to review the internal management systems relating
to Erosion Sediment Control. The members are outlined in Table 1 below. (include any expert consultants, and
external stakeholders involved eg Healthy Waterways, EPA etc)
Table 1: Members of the Internal Review Team
Name
Department
Role
Responsibility
Managerial Support
Managerial support was given on the (insert date) through the (insert meeting/memo/committee etc that gave
support for review to occur & attach supporting documentation if required).
3
Step 2: Rapid Desk Top Assessment
The following is a summary of the outcomes from ESC Rapid Assessment (the full Audit Tool Template can be
download from the Water by Design website).
Table 2: ESC Rapid Assessment Summary
Features of a best practice ESC
program
Current level of
performance
Strengths / Weaknesses of the
current program
Recommended actions to
improve performance
Very Poor  Very Good
[please tick one]
1. Political and executive support
    
2. Policy, planning controls and
development assessment
a) Ddevelopment assessment and
building approval process.
    
b) Council’s own ESC construction
and maintenance activities.
    
3. Compliance & Enforcement
    
4. Management systems
    
5. Resourcing
    
6. Awareness of ESC
a) Awareness within Council
    
b) Awareness within the broader
community
    
7. Specialist training
    
8. Audits to track performance
over time
    
9. Technology and innovation
    
10. Incentives
    
4
Step 3: ESC Policy Review
ESC Policy & Guideline Review
The documents outlined in Table 3.1 were reviewed against ESC best practice guidelines. A summary of the outcomes of this review are presented below.
Table 3.1: ESC Policy and Guideline Document Review – Data Collection Sheet
Other Comments/Issues
Is the document
Does the document reflect or reference Best (provide a short summary of any
easily accessible
Practice ESC IECA Manual? Does it go above issues with the document - more
and utilized by
and beyond? Provide Comments:
detail may be provided in a
staff/industry?
separate report)
Recommended
Follow-up Actions
Planning Scheme Policy, Codes & associated
ESC Guidelines
Standard Conditions for assessable
development
ESC self assessable codes/guidelines for lots
< 2500m2
Checklists/procedure for assessing ESC Plans
Development inspection and enforcement
procedures document for assessable
development
Development inspection and enforcement
procedures document for building sites /
Checklist for undertaking ESC Site Inspections
Fact sheets/educational material
5
Training and Education
The following details staff and industry qualifications in relation to ESC expertise.
(This Table provides a suggested template for the Council to record Staff and Industry ESC qualifications. Such a register might be used to record internal staff
training and to recognise training needs. It may also be used to determine whether an external consultant is suitably qualified to submit plans or whether a
contractor is suitably qualified to install ESC measures).
Table 3.2: Template for Register of ESC Suitably Qualified Persons (internal and external)
Name
Employer
Position
Role in ESC Process
(Compliance/DA/Plan Writer/
Plan Implementer)
Qualification
(inc date obtained)
Training
undertaken
Further
Training
Required
6
Step 4: ESC Plan Review
(insert number of plans reviewed) ___ ESC Plans were reviewed to determine compliance with Council policy and best practice standards.
Table 4: ESC Plan Review – Data Collection Sheet
#
Summary of Comments, Issues & Recommendations
Number of developments reviewed as part of this
audit
How many of these developments had ESC Plans
reviewed/approved by Council
How many of these ESC Plans were compliant with
policy/guidelines/best practice standards
How many of these ESC Plans had condition of
approval that were compliant with
policy/guidelines/best practice standards
How many of these ESC Plans were on high risk sites
(dispersive soils, steep slopes, acid sulphate soils etc)?
Of these high risk sites how many Plans had additional
controls / conditions to address the risk.
How many of the developments were / will be open
during the wet season? Of these developments how
many had ESC Plans with additional controls /
conditions to address wet season risks
How many of these ESC Plans were signed off by a
suitably qualified person/CPESC
*ESC Best Practice refers to the International Erosion Control Association - Best Practice Erosion & Sediment Control Manual http://www.austieca.com.au/
7
Step 5: ESC Compliance Process Review
ESC Site Inspection Results
(insert number of developments inspected) ___ developments were inspected to assess compliance with site specific ESC Plans.
Table 5.1: Compliance Review – Summary of Site Inspection Results
#
Comments
Number of Developments inspected
Number of Developments that fully complied with ESC plans and
controls were effectively managing erosion and sediment
Number of Developments that fully complied with ESC plans, but
controls were not effectively managing erosion and sediment
Number of Developments that mostly complied with ESC plans but had
a few minor non-compliances
Number of Developments that mostly did not comply with ESC plans
and had major non-compliances
ESC Site Inspection Photographs
The following are photographs of compliant and non-compliant construction sites.
(insert images taken of site inspections here)
8
Desk-Top Compliance Records Review
Compliance procedures and documentation were reviewed for (insert number of developments)___ developments.
Table 5.2: Compliance Review - Desk Top Assessment
#
Comments
Number of developments inspected that have had previous non-compliances
documented?
Number of developments issued with a written notice or regulatory notice to
address a minor non-compliance in the last 12 months
Number of developments with major non-compliance documented
Enforcement tools used to rectify a major non-compliances – specify:
Effectiveness of enforcement tools – non-compliance rectified within a week, within
a month, not at all.
Over the last 12 months how many of the following have been issued for ESC noncompliance (total for all developments with ESC plans approved by Council):
o Written request
o Show cause notice (SPA)
o Stop works notice (SPA)
o Action under EPA
What time frames have generally been given for developers to fix a noncompliance?
9
Step 6: Staff Survey
Instructions:
The following are Staff Survey Templates that can be used to collect data from DA Assessment and Compliance
Officer Staff on the topic of ESC assessment and compliance.
There are a number of ways the survey could be delivered to staff, however it is recommended that a survey
delivery and collation program such as Adobe FormsCentral or Survey Monkey be used so that the results can
remain anonymous, be automatically collated, easily downloaded and analysed. The following Staff Survey
Templates can be downloaded from the WbD website in the Adobe FormsCentral Format. If you have the
FormsCentral Program, use it to open the files, edit the survey content as needed and distribute the survey to
relevant staff. Once the staff have completed the survey their responses will be automatically collated by the
program and can then can then be downloaded into excel or pdf for further analysis. The FormsCentral
Program can be downloaded from
http://success.adobe.com/en/na/sem/services/1109_5958_formscentral.html for a nominal fee of $15 per
month.
If you do not wish to use a survey collation program you could alternatively cut and paste the text below into a
separate word document and deliver it to staff via email or hardcopy. Responses can then be manually
collated and analysed. However if this method is chosen, consider how the anonymity of the survey will be
maintained, and factor in the length of time data collation may take.
Once collated, the responses can then be summarised and inserted into this ESC Review Report Template. You
may like to present summarised data in graphs and/or tables, and extrapolate key ideas and anonymous
comments.
10
Development Assessment Staff Survey Template
Purpose: The following survey has been designed to provide staff involved in the assessment of Erosion &
Sediment Control Plans with the opportunity to comment on the ESC policy & assessment process, and to seek
suggestions for improvement. Please note that survey results will remain anonymous and will only appear in
reports as pooled statistical results, or as anonymous recommendations for improvement.
Questions:
1. Please indicated your involvement in the ESC Plan Assessment processes (more than one item can be
selected):
Assessing / Reviewing ESC Plans as part of the Development Assessment process
Writing Conditions of Approval for ESC Plans
Preparing / informing ESC Policy associated with Planning Schemes
Other
2.
Why do you think Erosion & Sediment Control is important?
To protect freshwater and marine environments
To protect stormwater infrastructure and reduce infrastructure maintenance costs
To improve social values and use of waterways and coastal environments, for example by improving
aesthetics and recreational experiences (eg swimming, fishing)
Other
3.
How do you rate your qualifications and knowledge of ESC?
Excellent (certified practitioner (CPESC), completed ESC training/up-skilling activities, and feel confident
interpreting and assessing plans, writing conditions and providing advice to planning, engineering and
industry)
Good (completed ESC training and feel confident interpreting plans and providing advice)
Average (completed ESC training and feel somewhat confident interpreting plans and providing advice,
however some extra training would improve confidence)
Have not completed ESC training and/or do not feel confident interpreting plans and/or providing advice
In which areas of ESC would you like to improve your skills & knowledge? _______________________
4.
How would you rate ESC performance in the region:
Excellent (better than best practice)
Good (best practice)
Poor (below best practice and generally non-compliant)
Unsure
11
5.
Do you feel Council ESC Policies comply with best practice standards - Best Practice Erosion & Sediment
Control Manual, produced by the International Erosion Control Association (IECA).
Yes
No
Unsure
Comments:_________________________________
6.
How would you rate compliance of submitted ESC Plans with best practice standards:
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
Comments:________________________________
7.
Overall, how would you rate the quality of submitted ESC Plans.
Excellent
Good
Average
Poor
Unsure
Comments:_______________________________
8.
Does Council insist that submitted ESC Plans are prepared by a suitably qualified professional (CPESC)?
Yes
No
Comments:_______________________________
9.
Does Council have a risk assessment process in place to identify ‘high-risk projects’ that require a high
level of ESC planning and management?
Yes
No
Unsure
If yes, what type of additional controls or conditions are placed on high risk development sites? (eg less
area opened at once, larger sediment basins, reduce earthworks during wet season, increased % of
stabilisation / ground cover?) ____________________________________________________
12
10. Do you feel Conditions of Approval for ESC Plans are in accordance with best practice standards?
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
If not, do you have ideas on how ESC Conditions could be improved? Would you like to make any other
comments regarding ESC Plan Conditions? __________________________________________
11. Please provide comments on how you think the ESC Plan assessment process can be improved to achieve
better quality plans and on-ground outcomes? _________________________________________
12. Do you feel there is strong political and executive support for establishing a high standard of ESC across
the region?
Yes
No
Unsure
Comments:____________________________________
13. Are there any other comments you would like to add? _________________________________
14. This survey is part of an Internal ESC Management Systems Review with the ultimate aim of improving
ESC implementation across the LGA. Do you have any comments on how the Internal Review Process or
this survey could be improved? Are there any other questions you feel need to be asked/answered as part
of this process? __________________________________________________________________
_______________________________________________________________________________
13
Development Assessment Staff Survey Results
(insert the pooled statistical survey results for reporting purposes eg graph, tables etc)
14
Compliance Officers Survey Template
Purpose: The following survey has been designed to provide staff involved in development compliance with
the opportunity to comment on ESC compliance process matters, and to seek suggestions for improvement.
Please note that survey results will remain anonymous and will only appear in reports as pooled statistical
results, or as anonymous recommendations for improvement.
Questions:
1. Please indicated your involvement in ESC Compliance on development sites (more than one item can be
selected):
Development Compliance Officer
Environmental Health Officer
Building Compliance Officer
Engineer
Planner
Other _____________________
2. Why do you think Erosion & Sediment Control is important?
To protect freshwater and marine environments
To protect stormwater infrastructure and reduce infrastructure maintenance costs
To improve social values and use of waterways and coastal environments, for example by improving
aesthetics and recreational experiences (eg swimming, fishing)
Other _____________________
3. How do you rate your qualifications and knowledge of ESC?
Excellent - Certified practitioner (CPESC). Completed ESC training/up-skilling activities. Feel confident
interpreting plans, identifying compliant/non-compliant sites, and taking enforcement action when necessary.
Good - Completed ESC training. Feel confident interpreting plans, identifying compliant/non-compliant
sites and taking enforcement measures when necessary
Average - Completed ESC training. Feel somewhat confident interpreting plans, identifying
compliant/non-compliant sites and taking enforcement measures when necessary
15
Have not completed ESC training and/or do not feel confident interpreting plans, and/or identifying
compliant/non-compliant sites, and/or taking enforcement action
Other _____________________
In which areas of ESC would you like to improve your skills & knowledge? _________________
4. How would you rate development site compliance with approved ESC Plans generally across the region:
All comply (100%)
Most Comply (80%)
Some Comply (50%)
Few Comply (<25%)
None Comply
Comments: ________________________________________________________________________
5. How would you rate the effectiveness of ESC on development sites where plans have been implemented?
Effective (run-off from site is virtually clear, erosion not obvious)
Medium effectiveness – (run-off from site is a bit muddy, erosion not obvious)
Not effective – (few controls in place, erosion is obvious, run-off is brown/muddy)
Comments: ________________________________________________________________________
6. Does Council have a self-assessable code for developments under 2,500m2?
Yes
No
Unsure
If so, do you know if this Code is implemented and complied with by the building industry? Could you
recommend how compliance may be able to be improved?__________________________________
7. What tools does Council use to deal with ESC non-compliance? How regularly are enforcement tools used,
for example on-the-spot fines, stop work notices and prosecutions for clear breaches of ESC development
conditions?
Every time a non-compliance is found an enforcement tool is used
Most of the time (80% of the time)
16
Some times (<50% of the time) and only if there is a serious breach
Enforcement tools for non-compliance have been used very little or not at all in the last 12 months
Comments:_____________________________________________________________________
8. If Council does not regularly use enforcement measures to address non-compliance, please outline the
measures that Council uses to achieve developer compliance. Have these measures been effective? How long
does it usually take for a developer to address a non-compliance using these measures? How do you think this
process could be improved? _________________________________________________________________
9. Do you feel there is strong political and executive support for establishing a high standard of ESC across the
region?
Yes
No
Unsure
Comments:_______________________________________________________________________
10. Do you feel Council provides sufficient resources (staff, funding, training etc) and support to adequately
undertake site inspection and apply regulatory / enforcement tools where necessary.
Yes
No
Unsure
Comments:_______________________________________________________________________
11. What do you feel are the barriers to ESC implementation and do you have any suggestions on how these
could be overcome? _______________________________________________________________________
12. What are the current drivers that encourage ESC implementation? _______________________________
13. This survey is part of an internal ESC management systems review with the ultimate aim of improving ESC
implementation across the LGA. Do you have any comments on how the Internal Review Process or this survey
could be improved? Are there any other questions you feel need to be asked/answered as part of this process?
17
Development Assessment Staff Survey Results
(Insert the pooled statistical survey results for reporting purposes)
18
Step 7: ESC Internal Management Systems Score Card for Councils
The following Score Card summarises Council’s overall ESC performance as determined by the results from the Internal Review Process.
A – above best practice; B – best practice C – Common practice, D/E-practices that are unacceptable by industry and community standards and/or do not meet
regulatory requirements
Table 7.1: ABDC Score Card - Council Processes for ESC Policy, Assessment, Approval and Compliance
Item
A
B
C
D/E
Score
5
4
3
1
Policy
ESC Policy/Guidelines/
Standard
Score
Sc
or
e
ESC Planning Scheme Policy meets SPP
requirements and reflects / references
IECA.
ESC Planning Scheme Policy
meets SPP requirements and
reflects or references IECA.
Planning scheme integrates
SPP requirements.
Not consistent with SPP or
best practice guidelines.
ESC Planning Scheme Policy goes beyond
best practice where necessary to suit
climatic conditions and achieve WQ
objectives (eg stop works during wet
season, regulate area and period of
exposure)
Erosion Risk
Assessment
x
1
Council has erosion risk maps for whole
of LGA.
Council has soil class maps of
LGA.
Council requires submitted ESC plans to
assess erosion risk.
Council requires submitted ESC
plans to assess erosion risk.
Qualified Staff ensure all submitted plans
Qualified Staff ensure all
Council requires submitted
ESC plans to assess erosion
risk
Council does not undertake
erosion risk assessments
and does not require
submitted ESC plans to
assess risk.
Staff assess plans against
Council does not require
1
Assessment
ESC Plan Assessment
2
19
T
ot
al
are consistent with the Planning Scheme.
Inconsistent plans are not approved.
Council provides guidance/procedures to
industry on how to develop ESC plans for
development sites.
Council provides staff with ESC plan
assessment procedures and training.
Qualifications of ESC
Plan Writer
Qualifications of
Council ESC Assessing
Officers
ESC Plan Conditions
submitted ESC plans are
consistent with the Planning
Scheme. Inconsistent plans are
not approved.
Planning Scheme.
ESC plans to be submitted
to Council and does not
provide guidance to
industry regarding the
minimal requirements
Council provides
guidance/procedures to
industry on how to develop ESC
plans for development sites.
Council only accepts plans from suitably
qualified professionals with CPESC
qualifications.
Council only accepts plans from
suitably qualified professionals
as defined by Council Guidelines
(eg completed an accredited
ESC Course)
Council accepts plans from
professionals (eg engineers)
who may or may not have
specific ESC qualifications.
Council has no
requirements for ESC plan
writers to be qualified
Staff assessing, approving and
conditioning ESC Plans are CPESC
qualified
Staff assessing, approving and
conditioning ESC Plans have a
degree in Engineering,
Environmental Science or
related discipline, and have
completed specific ESC training.
Staff assessing, approving
and conditioning ESC Plans
have a degree in Engineering,
Environmental Science or
related discipline but are not
required to have completed
specific ESC training.
Staff assessing, approving
and conditioning ESC Plans
are unqualified.
Conditions are consistent with,
and supported by best practice
guidelines (IECA, 2008).
Conditions are practicable,
measurable, and consistent for
all developments.
Conditions are consistent
with SPP but do not go
beyond this nor do they
incorporate IECA
recommendations.
ESC Conditions are not
consistent with SPP or
IECA, are not consistently
applied to all
developments, and are not
specific / measurable.
Conditions are consistent with, and
supported by best practice guidelines
(IECA, 2008). Conditions are practicable,
measurable, and consistent for all
developments.
Conditions go above best practice
guidelines on high risk sites to achieve
WQ guidelines (eg stop works during wet
season, regulate area and period of
exposure)
1
1
1
Compliance
20
Development
Compliance with Best
Practice Standards
Majority of developments (>80%) comply
with approved plans, best practice
standards, and install additional controls
where needed.
Majority of developments
(>80%) voluntarily comply with
approved plans
Some developments (<50%)
voluntarily comply with
approved plans
Few developments (<25%)
voluntarily comply with
approved plans
Development
Compliance Run-off
Water Quality (Mg/L)
Guidelines
50mg/L – Majority of developments
(>80%) comply with 50mg/L target
<100mg/L – Majority of
developments (>80%) have runoff concentrations of <100mg/L
<250mg/L – Majority of
developments (>80%) have
run-off concentrations
<250mg/L
>250mg/L – Majority of
developments (>80%) have
run-off concentrations of
>250mg/L
Compliance
Inspections and
Enforcement
Council routinely and frequently inspects
construction / development sites to
assess legislative compliance, and
follows-up on complaints.
Council routinely and frequently
inspects construction /
development sites to assess
legislative compliance, and
follows-up on complaints.
Council undertakes
inspections of development
sites, however rarely uses
enforcement tools to address
clear breaches of ESC
development conditions and
EPA 440ZG.
Council does not undertake
investigations to monitor
development compliance
and does not utilise
enforcement tools.
Council strategically use enforcement
tools such as on-the-spot fines, stop
work notices and prosecutions for clear
breaches of ESC development conditions
and Environmental Protection Act
s440ZG.
Council has a track record of successfully
enforcing ESC conditions and regulations,
as well as procedures, systems and
cultures that support successful
enforcement action.
Monitoring
For developments that are large scale
and/or high risk and/or have sediment
basin/s:
-
Council strategically use
enforcement tools such as onthe-spot fines, stop work
notices and prosecutions for
clear breaches of ESC
development conditions and
Environmental Protection Act
s440ZG.
For developments that are large
scale and/or high risk and/or
have sediment basin/s:
Council conditions the developer to report stormwater quality discharge
monitoring and ESC plan compliance
regularly to Council. Water Quality
monitoring is undertaken by a third
party at the expense of the
Council conditions the
developer to report
stormwater quality
discharge monitoring and
ESC plan compliance
regularly to Council. Water
2
2
2
For developments that are
large scale and/or high risk
and/or have sediment
basin/s:
-
Council does not require
developers to monitor
stormwater quality
discharge from their sites.
1
Council conditions the
developer to report
stormwater quality
discharge monitoring and
ESC plan compliance to
21
developer. Council follows-up to
ensure monitoring reports are
submitted and conditions are being
complied with.
-
Compliance staff
qualifications
In additional, the developer
financially contributes to Council’s
regional water quality monitoring
program, which includes WQ
monitoring during/after rainfall
events downstream of large
developments and high risk sites.
ESC Compliance Officers are CPESC
qualified
Quality monitoring is
undertaken by a third party
the expense of the
developer. Council followsup to ensure reports are
submitted and conditions
are being complied with.
Council.
-
However Council does
not actively follow-up to
ensure reports are
submitted and conditions
are being complied with.
ESC Compliance Officers have
completed specific ESC training
and have a good understanding
of ESC principles.
ESC Compliance Officers
have some understanding
ESC principles.
ESC Compliance Officers
have not completed
specific ESC training and do
not have a good
understanding of ESC.
1
There is some support for
establishing a best practice
standard of ESC across the city /
shire at political and executive
levels in Council.
There is some support for
establishing a high standard
of ESC across the city / shire
at political and executive
levels in Council.
Front-line staff feel supported
to insist upon a best practice
standard of ESC during
development assessment,
enforcement, construction or
maintenance activities.
Front-line staff would like to
feel more supported to insist
upon a high standard of ESC
during development
assessment, enforcement,
construction or maintenance
activities.
There is little support for
establishing a high
standard of ESC across the
city / shire at political and
executive levels in Council.
Front-line staff do not feel
supported and as a result
find it difficult to insist
upon a high standard of
ESC during development
assessment, enforcement,
construction or
maintenance activities.
2
Council provides sufficient staff
and funds to assess plans,
routinely inspect construction
Council provides some
resources for plan
assessment and compliance,
Council does not provide
sufficient staff and funds to
adequately assess plans,
2
Managerial Support
Political and Executive
Support
There is strong support for establishing a
high standard of ESC across the city /
shire at political and executive levels in
Council.
Front-line staff feel supported to insist
upon a high standard of ESC during
development assessment, enforcement,
construction or maintenance activities.
This has translated to a high degree of
ESC implementation.
Resourcing
Council provides sufficient staff and
funds to adequately assess plans,
routinely inspect construction sites, and
22
apply regulatory / enforcement tools
where necessary. This has translated to a
high degree of ESC implementation.
sites, and apply regulatory /
enforcement tools where
necessary.
however staff feel more
routinely inspect
support is needed to improve construction sites, and
the implementation of ESC.
apply regulatory /
enforcement tools. As a
result ESC is not being
implemented by industry.
Council has adequate initiatives in place
to ensure these people have a good
understanding of the significance of
erosion and sediment as a threat to
healthy waterways, what can be done to
manage erosion risk, and the relative
benefits vs costs of ESC. This has
translated to a high degree of ESC
implementation.
Council has initiatives in place
to educate these people on the
significance of erosion and
sediment as a threat to healthy
waterways, and what can be
done to manage erosion risk.
Council has a basic
community and industry ESC
education program (eg
educational information
available on Council website,
leaflets etc.), however there
is still a low level of
awareness of the threat
erosion and sediment pose
to waterways.
Awareness
Awareness within
Council (e.g. amongst
councillors, executives,
development
assessment officers,
enforcement officers,
construction and
maintenance staff,
etc.), and awareness
within the broader
community (e.g. local
builders, homeowners,
developers,
contractors).
Council does not have any
programs in place to raise
awareness of the
importance of ESC.
1
Total Score
Score Conversion:
A
B
C
D
E
90-100
70-89
50-69
30-49
<30
23
Table 7.2: ABDC Score Card – ESC Management Processes for Council Infrastructure Projects
Council ESC Performance
(for Council’s own
construction and
maintenance activities)
Policy and procedures
A
B
C
D
(4)
(3)
(2)
(1)
Council has policies and procedures in place
to ensure ESC standards on Council’s own
building, construction and maintenance
works represents best practice and set a
positive example for local stakeholders.
Council has policies and
procedures 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.
Council some policies and
procedures in place to
ensure that ESC
standards on Council’s
own building,
construction and
maintenance works meet
Environmental Protection
Act requirements.
Council does not
implement policies or
procedures to ensure ESC
is undertaken on
Council’s own building,
construction and
maintenance works.
Council produces ESC plans for
all their own
earthwork/construction
activities.
Council only produces
ESC plans for its own
earthwork/ construction
activities when the sites
have a high erosion risk
Council does not produce
ESC plans for its own
earthwork/construction
activities.
ES Controls are implemented,
monitored and maintained on
all sites.
ES Controls are
implemented only on
high risk sites
ES Controls are not
implemented, monitored
and maintained
The responsibility for managing ESC on
Council sites is clear.
Meaningful incentives / disincentives are in
place to ensure Council’s construction and
maintenance staff set a good example.
Planning
Council produces ESC plans for all their own
earthwork/construction activities.
Plans are prepared by a suitably qualified
professional (i.e. a Certified Professional in
ESC).
The responsibility for managing
ESC on Council sites is clear
Score
Council develops ESC concept plans prior to
letting a project for tender.
Implementation
ES Controls are implemented, monitored
and maintained on all sites.
Changes are made to controls as needed to
adjust to changing site conditions.
Site foreman is appropriately trained and
qualified to implement ESC Plans.
Council undertakes water quality monitoring
Changes are made to controls
as needed to adjust to changing
site conditions.
Site foreman is appropriately
trained and qualified to
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Revegetation/Stabilisation
during/after rainfall events downstream of
works.
implement ESC Plans.
Comprehensive site rehabilitation plan
developed for all sites
Most Council work sites
(including all high risk sites) are
adequately
revegetated/stabilised,.
Council ensures all works undertaken by or
on behalf of Council are adequately
revegetated/stabilised directly after works
are complete.
Only sites with high
erosion risk are
adequately revegetated/
stabilised.
Council work sites are not
being adequately
revegetated/ stabilised.
Score Conversion:
A
B
C
D
15-16
11-14
7-10
<7
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Step 8: ESC Action Plan
Table 8: ESC Action Plan Template
Annual Review
Item
Action
Problem
(as identified by review)
(the following are suggestions – Council may edit actions
to suit its needs)
Person responsible to
complete and report
on Action
Resources Manager
Timeframe
required Sign-off
Have actions been
completed within the
timeframe. Note any
challenges or deviations
from Plan.
Policy
ESC Policy/Guidelines/
Standard
Erosion Risk Assessment
Amend documents to current meet best practice
guidelines. Go beyond best practice where necessary to
suit climate conditions and achieve WQ objectives (eg to
address steep sites, dispersive soils, heavy rainfall)
Undertake and publish erosion risk assessment maps.
Produce a clear procedure for developers to undertake
erosion risk assessments (eg IECA procedures)
Assessment
ESC Plan Assessment
Qualifications of ESC
Plan Writer
Develop a procedure for ESC assessment that clearly sets
out:
-
Who in Council is responsible for assessing, preparing
information requests, preparing conditions and
approving ESC Plans in accordance with best practice
standards
-
Resources required to achieve adequate ESC
assessment
-
An ESC Plan Assessment Checklist to ensure plans
meet best practice
-
Other .....
Depending on the issue actions might include:
-
Write and implement a policy to ensure Council only
accept plans from suitably qualified professionals.
-
Gain managerial sign-off and support to refuse plans
not prepared by a suitably qualified person
-
Provide regular training to local industry
Qualifications of ESC
Plan Assessing Officers
Identify training and qualification gaps and provide
training to relevant staff. (define qualifications required)
ESC Plan Consent
Conditions
Prepare standard conditions that reflect best practice
guidelines (eg IECA standard conditions). Additional
conditions can be prepared for high risk sites.
Compliance
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Development
Compliance with Best
Practice Standards
Clearly communicate to industry how they are expected to
meet Council’s ESC requirements
Provide training opportunities for industry
Provide opportunities for industry to talk to each other
and to Council about ESC on an on-going basis to ensure
everyone is clear about requirements.
Run-off Water Quality
(Mg/L)
Train relevant staff on water quality monitoring
procedures and interpretation.
Compliance Inspections
and Enforcement
Prepare a Compliance Procedure for Staff that includes
how and when to: undertake compliance inspections; use
enforcement tools; and keep records of enforcement
actions.
This should ensure sites are routinely inspected and Staff
have clear direction and authority to use regulatory tools
to enforce conditions & EPA.
Develop a site inspection checklist to assist with
construction site audits (eg IECA Site Inspection Checklist)
Monitoring
Produce conditions that require developers to undertake
monitoring within and downstream of their own sites and
report results to Council. This information can be used to
determine if developers are complying with water quality
objectives, and can be used as evidence to enforce
conditions or undertake prosecutions if necessary.
Compliance staff
qualifications
Provide training and up-skill relevant staff. Councils should
define the qualifications required to undertake certain
roles.
Managerial Support
Political and Executive
Support
Action might include briefing Councillors on the current
situation and the findings of the audit. Imagery such as
photography from recent site inspection can help visually
represent compliant and non-compliant practices. This
could be followed-up by regular updates to Council on
improvements made to on-ground implementation of ESC
measures once the implementation of the Action Plan has
commenced.
Resourcing
Communicating the current situation and improvements
to Council should help to generate support and possibly
assist with gaining adequate resources to improve the
current situation. The Healthy Waterways ESC Cost Benefit
Analysis provides additional data that may also be useful
for demonstrating the benefits of ESC to Council (the
report can be downloaded from the WbD website).
Awareness
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Awareness within
Council (e.g. amongst
councillors, executives,
development
assessment officers,
enforcement officers,
construction and
maintenance staff, etc.),
and awareness within
the broader community
(e.g. local builders,
homeowners,
developers, contractors).
Develop education tools to:
-
assist with distributing information about
policy/procedural reforms that have come about as
a result of this process.
-
emphasise the importance of improving ESC
implementation (eg reduced waterway
maintenance costs, improved waterway health,
improved amenity etc).
Develop a report card on performance and
implementation of ESC and distribute report card results
to local developers and newspapers.
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Summary & Conclusions
(Council may wish to add text here that summarises the main findings and proposed actions...)
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