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Working Towards a Comprehensive Policy Framework for Managing Contaminated Land in New Zealand: Report on Submissions

Executive summary

1 Introduction

2 Overview of submissions

3 Key elements and work priorities

4 National environmental standards

5 Roles and responsibilities

6 Guidance

7 Liability

8 Accreditation

9 Capability

10 National information

11 Additional research areas

12 Additional opportunities

13 Workshop overview

Appendix A: Index of submitters

Abbreviations

References

9 Capability

The vast majority of submitters considered that a lack of capability in local government creates a significant barrier to the effective management of contaminated land. There was less consensus on whether there is a lack of capability within the consulting community.

A number of submitters suggested that issues of capacity and resourcing in local government were greater barriers than capability. The commonest suggestions for improving local government capability were: training, provision of funding/resources, leadership from central government, clarity of local government roles and responsibilities, guidance, and an accreditation or certification scheme for contaminated land practitioners.

There were also concerns about the variability in the quality of work from the consulting community and a shortage of skilled practitioners. The commonest suggestions for improving consultant capability included: training, an accreditation/audit scheme, and increased national leadership.

Capability in local government

Thirty-one (50%) submitters responded to this discussion point. Nineteen agreed that a lack of capability in local government forms a significant barrier to the effective management of contaminated land. Six submitters partially agreed with the discussion point and one disagreed. Figure 8 provides a breakdown of the responses.

Those who agreed or partially agreed suggested a range of factors for the lack of or variable local government capability, including:

• limited resources being devoted to contaminated land

• competing demands for resources within councils

• contaminated land is often not a priority for councils

• lack of experienced, qualified council staff.

Improving local government capability

Training was considered by the majority (14) to be the best way to improve local government capability. A number of suggestions for how training should be applied were made, including:

• making contaminated land issues part of wider RMA practitioner training

• training on the use of the Hazardous Activities and Industries List (HAIL) and on where to find information on contaminated land, as well as training on the appropriate control of subdivision and land use

• training in geology, hydrogeology and environmental chemistry

• training on the legislation relevant to contaminated land.

Many submitters (8) suggested that increased leadership from central government would improve local government capability. They considered that better leadership could be provided by providing a comprehensive policy framework that contains consistent methodology, supported by expert advice (eg, a centre of excellence, or policy advisory group).

Seven suggested that providing funding or resources would improve local government capability, especially in smaller councils.

A range of other measures were suggested to improve local government capability. Common suggestions included:

• clarifying roles and responsibilities via guidance or legislative amendment (6)

• measures to support and resource local government to manage land information (4)

• guidance on the acquisition, handling and transfer of information and district plans (5)

• an accreditation/auditor/certification scheme to assist in local government capability (5)

• improving links/communication between councils/practitioners and other agencies (3).

Table 20: Suggestions for improving local government capability, by submitter ID

Capability of the consulting community

Twenty-one (34%) submitters responded to this discussion point. Ten agreed that a lack of capability in the consulting community forms a significant barrier to the effective management of contaminated land. Four respondents partially agreed with the discussion point and three disagreed. Four submitters did not specifically address this question but offered suggestions as to how consultant capability could be improved. Figure 9 provides a breakdown of the responses.

Those who agreed or partially agreed suggested a range of factors for the lack of or variable capability, including:

• a shortage of skilled practitioners, especially in areas outside the main population centres

• lack of training opportunities for consultants, and no formal qualification for contaminated land practitioners

• shortage of staff and variable skills puts pressure on consultants, affecting time and cost.

Improving capability within the consulting community

Training/education was the most common suggestion (15) to improve capability within the consulting community. Suggestions for how training/education should be provided included:

• training, seminars and workshops by the Ministry and universities to raise awareness of legislation and the requirements of consultants in relation to the legislation

• guidance for students on subjects useful for contaminated land management careers.

Six submitters suggested that an accreditation/audit/certification scheme could improve capability. Four suggested increased leadership from central government would improve capability. It was considered that such leadership could be provided by requiring a high standard of investigation and reporting by local government, providing a comprehensive policy framework containing consistent methodology, and supported by expert advice or a centre of excellence.

Table 21: Suggestions for improving consultant capability, by submitter ID

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