House of Representatives Committees

Environmental Management of Commonwealth Land

APPENDIX C: RESPONSES TO AUDIT REPORT NO 31 1995-96

No ANAO Recommendation Responses to recommendations
and follow-up action
1 Commonwealth Policy

That the CEPA* should, as a matter of priority, develop a proposal for Ministerial consideration to clarify the Commonwealth's policy position on Commonwealth contaminated sites.

CEPA - Agreed in principle but CEPA will not be undertaking tasks associated with contaminated sites due to changes to its priorities.

DoD* - Agreed.

DCA* - Agreed.

DAS* - Agreed.

DTRD* - Supported in principle. Noted the work of the NEPC*.

2 Environment Management Systems

That land managing entities address pollution prevention, detection and remediation in accordance with best industry practice. A well-developed Environment Management System, such as that outlined in the summary of current better land management practice, may assist entities in this regard and provide a useful framework for the ANZECC/NHMRC Guidelines detailed in the audit report.

DoD - Agreed. Defence is going through the tendering process to select a supplier to develop a corporate EMS*. The supplier will also develop a corporate EMP* with accompanying best practice guidelines. Defence Instruction on Environment and Heritage Protection is under review and Instructions on Environmental Management and Contamination Prevention and Management are being developed.

DCA - Agreed. The NTA* is conducting an environmental survey of all sites which will allow planning and development of an EMS. Australia Post has an EMS in place. Telstra has substantially completed implementing an EMS.

DAS - Agreed in principle. DPG* is assessing the level of contamination of the sites over which it has control, and a database structure on which to record the information collected against which a continuous improvement process would be based.

CEPA - Agreed in principle. CEPA will not be undertaking tasks associated with contaminated sites due to changes to its priorities.

3 Department of Defence

That the DoD, as a matter of priority, develop and implement an effective, departmental-wide, environment policy instruction as part of the implementation of an EMS and systematic risk management, as suggested in the better practice guide in Appendix 2 of the audit report.

DoD - Agreed. An Environment Policy Statement has been drafted which will represent the cornerstone of the corporate EMS. The draft policy statement and accompanying guiding principles handbook is under review by the Defence Environment Forum Working Group.
4 That DoD:

(a) commit to the introduction of integrated EMPs by the end of 1997 for all sites with high-risk characteristics as identified in the internal Management Audit Branch review. These EMPs should be integrated into the Defence Management System and include quantitative performance indicators, review, and reporting mechanisms;

(b) dispose of hazardous materials according to recognised best practice. Defence should review its on-site disposal of hazardous materials and introduce a program to identify and remediate high-risk sites as soon as possible. Resource allocations should be linked to identified risks such as the degree of risk to human health and the potential for off-site movement of contaminants; and

(c) conduct a cost-effective training needs assessment across the portfolio to facilitate the development of training modules on environmental management procedures and objectives for relevant personnel.

DoD - Agreed.

(a) EMPs are being prepared by Programs within Defence for their facilities, with priority being given to those sites most under pressure. Draft Defence Instruction Environmental Management is designed to ensure that EMPs are prepared according to standard formats, and that performance indicators and reporting mechanisms are included.

(b) It is DoD policy to comply with the intent of relevant State and Territory legislation with regards to hazardous waste disposal. Defence Instructions are in place to address hazardous waste disposal.

(c) Efforts have been made to raise awareness through OH&S training and awareness programs. All three Services use in-house and industry programs to ensure personnel handling hazardous materials are appropriately trained in safety, handling and emergency response techniques.

5 That the DoD nominate a Senior Executive Service officer with a sound appreciation of environmental management practices to:

(a) chair the Defence Environment Forum;

(b) have prime responsibility for portfolio-wide environmental coordination and policy as the major component of his/her duties; and

(c) have responsibility for focusing strategic, portfolio-wide environmental actions and reporting so as to raise the status and priority of environmental matters such as pollution prevention, detection and remediation as appropriate.

DoD - Agreed. The First Assistant Secretary Facilities and Property has oversight of environmental issues within the Defence portfolio. The Defence Environment Forum consisting of senior representatives from the eight programs within Defence has been established. The Forum is supported by the Defence Environmental Working Group. The objective of the Forum is to provide a channel of communication, coordination and endorsement of the environmental effort across the Defence organisation.
6 That the DoD:

(a) develop and maintain a management information system that will allow it to record and use site contamination information to improve environmental and financial performance.

(b) in consultation with other Commonwealth Contaminated Sites Steering Group members, progressively introduce benchmarking of environmental performance to enable the Department to keep pace with developments in best practice both across the Commonwealth and in relation to private industry best practice; and

(c) introduce regular, independent environmental audits of high risk sites, such as those conducted by the Management Audit Branch, every two to three years.

DoD - Agreed with 6(a) and agreed in principle with 6(b) and 6(c).

(a) the development of an environmental management information system has been under development for some time. Currently, Air Force facilities are recorded on a CAD* system. Most Army and Navy facility managers also use Computer Aided Drawing systems for planning and management of their facilities and bases. UXO contamination records are maintained on a database linked to a Geographic Information System.

(b) Defence believes it has been at the forefront of developing policy and best practice on contaminated sites. Contamination assessments and remediation actions have been undertaken in close association with State environmental protection authorities.

7 That the Department of Defence:

(a) review the priority given to addressing UXO contamination of non-Commonwealth land;

(b) develop strategic and operational plans for dealing with UXO issues that set site assessment priorities based on appropriate criteria, allocate sufficient resources and include timetables for completion; and

(c) develop and finalise administrative procedures with State jurisdictions for site assessments and agreed hazard reduction operations.

DoD - Agreed in principle.

(a) The Commonwealth is not considered to be liable for continuing effects of UXO contamination on land where the Commonwealth has never had, or has disposed of, a legal interest. The Commonwealth may, however, determine that the level of UXO contamination is to be reduced.

(b) Defence proposes to develop a coordinated national approach to the management of information which will assist in the assessment process used to ascertain the nature and extent of UXO contamination and the options for remediation works.

(c) Consultative arrangements are in place with a number of States on the management of UXO contamination.

8 Domestic Property Group

That DPG, in consultation with the CEPA and major Commonwealth land users as appropriate, develop for consideration by Ministers a mechanism to ensure that all Commonwealth sites notionally owned by DPG are handed over to DPG in at least the same environmental condition as they were acquired.

DAS - Agreed in principle. DPG has not yet started implementation pending the outcome of a review of its properties. Financial arrangements will be paramount in getting cooperation from agencies.
9 That DPG enhance its draft environmental plan to include:

(a) quantifiable targets and firm but realistic timeframes for DPG's proposed actions to address its contamination risk assessment and other stated strategies; and

(b) a program of continuous improvement in respect of the sites directly managed by DPG that will allow DPG to:

(i) regularly assess its environmental management performance (with particular emphasis on land management) by benchmarking internally (between regional offices where appropriate) and externally (e.g. other land managing organisations); and

(ii) develop and conduct a regular program of environmental audits of high risk sites that would examine, among other things, pollution prevention and contamination management issues.

DAS - Agreed in principle. DPG has approached a consultant for a proposal for an audit of sites within the Public Interest Estate. The extent of contamination and the need for remediation will then be taken into account in developing individual management strategies.
10 That DPG:

(a) conduct an environmental training needs assessment across all levels within DPG with respect to pollution prevention and site contamination issues by the end of the 1996-97 financial year; and

(b) in the future regularly address the environmental training and information needs of its staff.

DAS - Agreed in principle. The environmental training and information needs of the Public Interest/Industrial & Special Purpose Estate team will be addressed through a specially developed training course commencing in 1996-97.
11 That DPG develop and maintain a management information system that will allow it to record and use site contamination information to improve DPG's environmental and financial performance. DAS - Agreed. DPG has commissioned the development of a database on which to record details about properties in the Public Interest/Industrial & Special Purpose Estate. It was expected the database will be operational in the second quarter of 1996-97.
12 Industrial Sites - Department of Communication and the Arts

That the National Transmission Agency, in consultation with the CEPA and other relevant Commonwealth entities storing PCBs*, continue to explore permanent and cost-effective solutions to safely dispose of or destroy its PCB residues.

DCA - Agreed. DCA is in consultation with Commonwealth and State EPAs for the destruction of PCB and PCB contaminated materials. A NTA/DPG joint task force will consider the management of NTA land at eleven major transmitting sites.

DAS - Agreed. DAS has contributed to the development of the proposed PCB management plan.

13 That the DCA develop a specific plan and timetable to address the problems raised and concerns contained in its Environmental Risk Assessment Report. DCA - Agreed. Action is either in train or planned. An audit of progress has been incorporated in the Department's 1996-97 Audit Work Plan.

DAS - Agreed. The DPG is a notional owner of properties occupied by the DCA.

14 GBE oversight by Departments

That as part of GBE* accountability and oversight processes and in the absence of any other oversight mechanisms, departments become more proactive in overseeing GBE operations that impact on the environment (with particular reference to contaminated sites) operations requiring oversight are those that are likely to affect the achievement of GBEs' financial and environmental targets, or expose GBEs or the Commonwealth to significant risk. In particular Departments, in association with their Minister, should reinforce with portfolio GBEs:

(a) the Government's expectations of GBEs' environmental responsibilities; and

(b) the need to keep the Minister and the portfolio department aware of environmental management issues, both as they arise (on an exception basis) and as part of the annual report and corporate planning and reporting processes.

DCA - Agreed in principle. Australia Post did not see any need for an increased oversight role for departments as it was already subject to all State and Local Government environmental protection legislation and accountability mechanisms under the Commonwealth Australian Postal Corporation Act 1989.

DTRD - Agreed in principle. DTRD supported that which seeks reinforcement between departments and GBEs as in 14(a) and 14(b). In regard to overseeing GBE operations that impact on the environment, DTRD indicated that day-to-day managing and monitoring of environmental issues is the responsibility of individual GBEs.

15 State environmental regulations

That the Commonwealth land managing entities and their tenants have full regard to State and Territory environmental regulations:

(a) where practicable, to prevent pollution; and

(b) as soon as off-site contamination/pollution or unacceptable human health risks are suspected or identified.

DoD - Agreed. DoD observes the intent of and complies with relevant State and Territory legislation wherever possible and practicable.

DCA - Agreed. Telstra is exempt from certain State and Territory laws while engaging in certain activities. However, its longer term interest is to have regard to these laws. Australia Post is required to comply with all State and Territory legislation on environmental issues.

DAS - Agreed.

CEPA - Agreed in principle.

16 Coordination Council on the Release of Commonwealth Land

That DPG, as the Chair of the Coordination Council on the Release of Commonwealth Land, raise with the Council the need to:

(a) further expand on its reporting of the impact of environmental issues (including site contamination) on the Commonwealth Property Disposal Program; and

(b) encourage land managing entities to identify in more detail any environmental and contamination issues for each property scheduled for disposal.

DAS - Agreed in principle. The future role of the Council was unclear. The issue of a coordinated source of information on Commonwealth property holdings has been raised previously at the Council and is likely to be addressed again. The need for information regarding environmental issues on sites scheduled for disposal can be addressed in that context.

CEPA - Agreed in principle. CEPA will not be undertaking tasks associated with contaminated sites due to changes to its priorities.

17 Contaminated Sites Steering Group

That the CEPA, in consultation with members of the Contaminated Sites Steering Group, provide strategic advice to Commonwealth land managing entities on the implementation of the Commonwealth Government's environmental policies and best environmental practices with respect to land management in general and site contamination in particular.

DoD - Agreed. Defence felt that the EPA was the most qualified organisation to carry out policy development.

DCA - Agreed.

DAS - Agreed in principle. DPG is interested in being involved in the implementation of this recommendation.

CEPA - Agreed in principle. CEPA will not be undertaking tasks associated with contaminated sites due to changes to its priorities

18 Independent audits

That Commonwealth land managing entities, as part of the Portfolio Evaluation Strategy, consider the value of having their environmental performance audited independently to protect the value of the Commonwealth's assets and demonstrate their commitment to protecting the environment.

DCA - Agreed. Australia Post is considering the certification of its EMS which would involve a periodic external audit of the system. Telstra agrees in principle to external auditing but is reliant on further progression of the EMS.

DAS - Agreed.

DoD - Agreed in principle. It is DoD's philosophy that EMPs are assessed on their relevance every three to five years at the discretion of the commanding officer managing the site. Audits are usually undertaken by independent environmental consultants.

CEPA - Agreed in principle.

* Key

CEPA Commonwealth Environment Protection Agency

DAS Department of Administrative Services

DCA Department of Communications and the Arts

DoD Department of Defence

DPG Domestic Property Group

DTRD Department of Transport and Regional Development

EMP Environtment Management Plan

EMS Environment Management System

GBE Government business enterprise

NEPC National Environment Protection Council

NTA National Transmission Agency

PCB Poly-chlorinated biphenyl

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