October Newsletter

Monitor the source, or the outcome?

It’s time to rethink our approach!

This month’s ALGA ecoforum was fantastic for meeting existing and new industry friends and learning about all things related to contaminated land and groundwater (well done ALGA!). It was an intense three days, made more so by the realisation that:

1. We know there are lots of contaminants that we discharge into the environment, but a lot of them are not monitored due to technical difficulty or because they are too expensive. This means we have a narrow focus and knowledge on the contaminants that we can measure, but there are a lot of unknowns.
2. For those contaminants that we can measure we have established criteria, however, there are concerns about the veracity of some of these criteria. That means we know they are problems, but we are not sure how to manage them.

Not meaning to scaremonger, but it seemed to me that some of the smartest people in the room were the most worried! We have an overwhelming number of contaminants, which we call Contaminants of Emerging Concern (CECs), and an increasing awareness that the problem is much bigger than we ever thought.

In this context, the changes in regulation in Victoria Environment Protection Act 2017 and the introduction of the General Environmental Duty (GED) at the centre of the Act, which states “You must reduce the risk of your activities potentially harming the environment or human health through pollution or waste” makes a lot of sense. Surely, we are better to minimise discharges rather than trying to justify emissions based on an infinite number of compounds (some still emerging) and reliable criteria yet to be developed.

From a monitoring perspective, operational metrics such as levels in storage ponds, flows, etc. are likely to be more realistic to implement and more useful than compound-specific analyses. In other words: Is it easier to monitor for a leak and quantify the leak, or to monitor the consequence of the leak?  It’s time for a rethink on our approach to monitoring.

Cheers,

Richard