December 2023 review and update
1. Part 2A of the Environmental Protection Act 1990 (Part 2A) came into force on 1 April 2000. This established a new statutory regime for the identification and remediation of contaminated land.
2. Under Part 2A each local authority has a duty to inspect its area for contaminated land. Leeds City Council published its first Contaminated Land Inspection Strategy in June 2001. Following a review of the 2001 Inspection Strategy, the January 2013 Contaminated Land Inspection Strategy was published, followed by October 2018 version a copy of which is attached as Appendix A.
3. This review of the October 2018 Inspection Strategy has been carried out following five full years of its implementation. In this review it is not proposed to update the 2018 Inspection Strategy document itself as there have been no fundamental changes to the technical and legal approach to inspecting Leeds for contaminated land, nor to the characteristics of the Leeds area. Whilst it is acknowledged that some sections could be updated, for example, Chapter 2 Existing Council Policies and Statutory Functions, these updates are not considered necessary at this current time given service priorities and resource constraints. However, please refer to the following Amendments and Updates sheet, attached as Appendix B, that identifies some updates that should be read in conjunction with the 2018 Contaminated Land Inspection Strategy.
4. At the time the March 2013 Inspection Strategy was published, service provision was allowing detailed inspection of approximately 20-30 sites a year. Over the past ten years, detailed inspection work has been taking place although at a much reduced rate due to service priorities (focussing on increasing planning consultation workloads) and resource constraints (reduced staffing levels).
5. In meeting the council's obligations under Part 2A, work will be continued in line with the Inspection Strategy. It continues to be difficult to estimate when detailed inspection for the whole of Leeds will be complete and at what rate sites will be investigated. Moving forward, available staff and financial resources will focus on the completion of sites that have been started.
6. As the Inspection Strategy is fundamentally remaining the same technically, a consultation process is not considered necessary. Following approval by the council (via delegated decision by the Chief Planning Officer in consultation with the Executive Member for Sustainable Development and Infrastructure), this review has been published and formally adopted on 12 December 2023.
7. The Contaminated Land Inspection Strategy will continue to be reviewed on a five yearly basis or less, where necessary, until routine detailed inspection of the Leeds area is complete.
8. Please note that the contact details for enquires about the Inspection Strategy have been changed. Please address any queries to the:
Team Leader (Contaminated Land)/Project Officer (Contaminated Land)
City Development
Merrion House
110 Merrion Centre
Leeds LS2 8BB
Tel: 0113 378 7608 or 0113 378 9865
Email:
contaminated.land@leeds.gov.uk
Appendix A Contaminated Land Inspection Strategy dated October 2018
Please refer to
Inspection strategy for Leeds.
Appendix B Amendments and updates sheet
The Contaminated Land Inspection Strategy 2018 has been reviewed in autumn 2023. Following this review, only a small number of amendments and updates were considered necessary. As a result, this amendments and updates sheet provides a summary of the outcome of this review. Whilst the CLIS still remains the 2018 version, the CLIS should be read in conjunction with this Amendments and Updates Sheet. The format of referencing below follows the Sections and Appendices of the CLIS 2018 report.
Section 1. Background and regulatory context
No necessary changes have been identified.
Section 2. Existing Council policies and statutory functions
The Best City Ambition replaces certain policies referred to in Section 2 including: Leeds 2030 - Vision for Leeds 2011 to 2030, the Best Council Plan and the Environment Policy 2012-2015. The council's Estate Management Strategy 2021 appears to replace the Asset Management Plan 2014-2017.
Para 2.9 - As of December 2023, the council's plans and priorities are available within the Leeds Best City Ambition (Leeds Best City Ambition.pdf). One of the priorities of the Best City Ambition is that Leeds will be a healthy city for everyone by 2030 with people living healthy lives for longer. The council's CLIS contributes directly towards this ambition. Although the implementation of Part 2A is a statutory duty, as opposed to a strategic priority or decision, the carrying out of the Inspection Strategy will help to enable the council to fulfil these priorities.
Para 2.12 and 2.38 - Public Health England has now been incorporated into the UK Health Security Agency (UKHSA).
Para 2.22 - The National Planning Policy Framework is now dated 2023 however the content of this publication has not significantly changed for land contamination matters.
Section 3. Characteristics of the Leeds Area
Section 3.7 (population) -2021 census data indicates population is around 812,000 for the Leeds district.
Para 3.43 - There are currently 107 Local Wildlife Sites. SEGI/LNA sites have now been assessed and have either been reclassified or removed.
Para 3.53 - There are currently 7 active and 2 dormant mineral extraction sites in Leeds. To date no planning permission has been sought for shale-gas extraction in Leeds.
Section 4. Aims objectives and priorities
No necessary changes have been identified.
Section 5. Strategy outline and work programme
Under the Inspection Strategy documents dated June 2001, January 2013 and October 2018, the following detailed inspection, determination and remediation work has been carried out:
| Part 2A activity - Jun 2001 to Dec 2012 | No. of sites | No. of properties* |
|---|
| Detailed inspection completed | 114 | 3,123 |
| Determination of contaminated land | 4 | 48 |
| Remediation of contaminated land | 4 | 48 |
| Part 2A activity - Jan 2013 to Oct 2018 | No. of sites | No. of properties |
|---|
| Detailed inspection completed | 64 | 1193 |
| Part 2A activity - Nov 2018 to Dec 2023 | No. of sites | No. of properties |
|---|
| Detailed inspection completed | 18 | 895 |
Section 6. Prioritising sites for inspection
No necessary changes have been identified.
Section 7. Carrying out detailed inspection
No necessary changes have been identified.
Section 8. Leeds City Council land
No necessary changes have been identified.
Section 9. Providing information to third parties
Para 9.10 - updated contact details are provided in Paragraph 8 in the December 2023 Review and Update section above.
Section 10. Responding to information from third parties
Para 10.16 - updated contact details are provided in Paragraph 8 in the December 2023 Review and Update section above.
Section 11. Inspection strategy review
No necessary changes have been identified.
References
Department for Communities and Local Government. ‘National Planning Policy Framework’. September 2023 (replaces 2018 version).
Appendix A Receptors
No necessary changes have been identified.
Appendix B Receptor Classification and Scoring Scheme
No necessary changes have been identified.
Appendix C Site Classification and Scoring Scheme
No necessary changes have been identified.
Appendix D Prioritisation Scoring
No necessary changes have been identified.
Appendix E
Procedures for carrying out detailed inspection will be based on documented techniques, including those detailed in the following publications. NB: this list is not exhaustive, but is indicative of key reference sources which are available at the time of publication of this document.
- ATRISK Soil SSVs Notes for Use. Atkins. March 2017.
- British Standards Institute. BS 8485:2015:A1:2019. ‘Code of practice for the design of protective measures for methane and carbon dioxide ground gases for new buildings. 2019.
- British Standards Institution. BS 10175:2011+A1:2013+A2:2017. Investigation of Potentially Contaminated Sites - Code of Practice. 2017.
- British Standards Institution. BS 5930:2015+A1:2020. ‘Code of Practice for Site Investigation. 2020.
- Building Research Establishment. Special Digest 1. ‘Concrete in aggressive ground. 3rd edition. 2005.
- Construction Industry Research and Information Association. C665. ‘Assessing risks posed by hazardous ground gases to buildings’. 2007
- Construction Industry Research and Information Association. C733. ‘Asbestos in soil and made ground: a guide to understanding and managing risks. 2014.
- Department of the Environment (DOE). Industry Profiles. 1995/1996/2006.
- Environment Agency. ‘Remedial Targets Methodology - Hydrogeological Risk Assessment for Land Contamination’. 2006.
- Good practice for risk assessment for mine gas emissions. CL:AIRE. October 2021.
- Ground Gas Handbook. ISBN 978-1904445-68-5. 2009. Wilson, S., Card, G., Haines, S
- Land Contamination Risk Assessment. Environment Agency. July 2023.
- Normal Background Concentrations (NBCs) of contaminants in English soils: Final project report. British Geological Survey (BGS) Commissioned Report, CR/12/035. Johnson, C.C., Ander, E.L., Cave, M.J., and Palumbo-Roe, B. 2012
- Professional Guidance: Comparing Soil Contamination Data with a Critical Concentration. Contaminated Land: Applications in Real Environments (CL:AIRE). 2020.
- Reference Publications for Detailed Inspection Procedures
- Retrofitting hazardous ground gas protection measures in existing or refurbished buildings. Publication C795. CIRIA. 2020
- Soil Quality - Sampling. BS ISO 18400-104:2018. British Standards Institute. 2018.
- Soil quality. Conceptual site models for potentially contaminated sites. BS EN ISO 21365:2020. BS1. June 2020.
- SP1010: Development of Category 4 Screening Levels for Assessment of Land Affected by Contamination - Final Project Report (Revision 2). Contaminated Land: Applications in Real Environments (CL:AIRE). 24 September 2014
- SP1010: Development of Category 4 Screening Levels for Assessment of Land Affected by Contamination - Policy Companion Document. Defra. March 2014.
- Technical Guidance Sheet (TGS) on normal levels of contaminants in English soils. Copper. TGS03. July 2012. Defra and BGS.
- The LQM/ Chartered Institute of Environmental Health (CIEH) S4ULs for Human Health Risk Assessment. Land Quality Management Limited (LQM)/CIEH. 2015.
- UK Soil and Herbage Pollutant Survey. UKSHS Report No.1. Defra. June 2007.
