CO2 mine gas - site investigation and risk assessment: best practice

With respect to applications for developments that may be affected by mine gas, tell us about how the relationships between the different parties work? [each party to answer in turn]

What does/ does not* make them effective?

P:

Factors that may be relevant:

• Good working relationships
• Multi-disciplinary departments
• Openness/ transparency
• Trust
• Formal written procedure
• Electronic records

Any thoughts on opportunities to improve communication or working relationships between departments?

BS:

EHO/ CLO:

What information is routinely (proactively) shared between the three parties (i.e. Env Health, Planning and Building Standards)?

If information is not proactively shared, but you have access to each other's departmental database, do you routinely check what information is held for a property by another department?

P:

Examples could include

• GIS layers
• CA data
• CA consultee responses
• Submitted reports
• Decision Notices

Do you all use the same database for recording data against a property gazetteer? Do you each have access to the other departments database?

Who (proactively) shares that information with the other parties and when is it shared?

How is this information shared and is that sharing recorded?

Any ideas for how the information sharing could be improved?

BS:

EHO/ CLO:

On receipt of

a Building Warrant application what is the process for checking whether there is a related planning application?

For linked applications who leads the review of SI reports etc.? Does building standards rely on reviews already done on behalf of planning?

BS:

How do you check the related submission?

• ·Shared database
• ·Email / phone / conversation.

Possible actions after checking:

• ·Agree a co-ordinated response if both applications have been submitted?
• ·Share reports and the review of those reports (see Q4 also)?
• ·Record this (how?) for future reference if only one application has been made?

P:

EHO/ CLO comment:

If a report is submitted to accompany either application, who reviews that report? – see report types

1. Desk studies / site investigations?

P/ CLO/ BS*

2. Remediation method statement / strategy (RMS)?

P/ CLO/ BS*

3. Design reports (DR - BS 8485) and drawings for gas protection measures?

P/ CLO/ BS*

4. Verification reports (VR)?

P/ CLO/ BS*

Do you require the same report to be submitted for each application, or do you advise the applicant the LA has already received / reviewed the relevant report?

If you receive a report directly do you check if it has already been submitted and reviewed by another department?

How does the person reviewing the report share their findings between department (if they do so)?

What processes are in place to ensure that where an amendment to the building warrant for the foundation design does not provide a risk of creating pathways for mine gas previously not considered.?

How do planning, environmental health and building standards coordinate to ensure this does not happen?

P:

When reviewing the reports (desk study & SI, RMS, DR, VR) do you consider implications for mine gas migration to existing off-site receptors in relation to a proposed new-build development (noting Building Standards condition 3.1)

Do you require evidence that all monitoring boreholes that represent possible pathways for gas migration will be sealed before development?

• If so how do require / condition this?
• If so how do you evidence compliance with this?
• Do you share this evidence with other departments?

BS:

EHO/ CLO:

Conditions

[depending on response to online survey]

In your experience, do you consider generic land contamination planning or building warrant conditions cover potential mine gas risks sufficiently?

P:

What are your individual views on the benefits of standardised planning conditions or building warrant requirements specific to mine gas?

If you use mine gas specific conditions, would you be willing to share a copy with us?

BS:

EHO/ CLO:

Can you tell us about any cases where problems were encountered during the design or verification stage relating to appropriate assessment or mitigation of mine gas risks?

What are your reviews on relying exclusively on submitted verification reports to evidence compliance?

P:

In which type of report?

BS:

EHO/ CLO:

8

Supplementary questions (time permitting)

P: In your opinion does your LA contaminated land guidance or the EPS guide need to be revised to address mine gas issues specifically?

BS – if yes, in what level of detail?

EHO / CLO – if supplementary guidance is required, what sort of level of detail / content are you looking for (if you have any opinion)?

BS: In your opinion does the Building standards technical handbook need to be revised to cover ground/ mine gas issues specifically?

EHO/ CLO: In your opinion is supplementary technical guidance required to address mine gas issues specifically?

Have you read or reviewed the draft CL:AIRE technical note recently issued for consultation?

Do you have anything else to add on good

practice with regards to the Planning and Building Standards approach to developments where there are potential risks associated with mine gas.

Any other areas for improvement?

P:

BS:

EHO/ CLO: