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Guidance update: The changing role of the Environmental Clerk of Works

18 Oct 2023

Heads of Planning Scotland have released a revised guidance note to advise Local Planning Authorities and the Energy Consents Unit on the role, responsibilities, and effective engagement of an Environmental Clerk of Works (EnvCoW).

Creating a narrative of environmental stewardship

In our latest insight, “The future of construction phase environmental management and the changing role of the Environmental Clerk of Works”, we discuss the significant shift towards outcome-based environmental assessments, Biodiversity Net Gain and Carbon Management requirements and an effort to prevent Green Washing. In this evolving landscape, the onus for achieving specified environmental outcomes—and substantiating them with evidence—will increasingly fall on developers and their construction partners.

To date, the role of the Environmental Clerk of Works (EnvCoW) has become somewhat of a catch-all term. The multi-faceted responsibilities placed on the Environmental Clerk of Works, often reduces the effectiveness of the role. Procurement practices that see the developer or contractor engage an EnvCoW can result in biased or conflicted reporting given pressures of working for but reporting on the client/contractor. Clarifying the role, it’s responsibilities and engagement method is crucial for shining a light on a project’s environmental performance. Transparent compliance reporting allows for an unconflicted feedback mechanism for impact assessments, while also offering an independent evaluation of a developer or contractor’s performance.

The aim of this updated guidance is to provide clear insights into the role of an EnvCoW, covering:

  • Its specific function and limitations

  • Its appropriate timing within the planning process

  • Best practices for procurement

  • Criteria for determining when the role is required

You can download your copy via the link included at the end of this news statement.

Simon Knott, Director at Naturally Compliant, played a significant role in revising this guidance note. He observes, “Traditionally, the role of the Environmental Clerk of Works has been muddled with various responsibilities and expectations. This has led to various challenges for the industry with the EnvCoW somehow responsible for advising/delivering and or ensuring compliance, while also reporting on the projects compliance, effectively marking their own homework.
The industry simply can’t say what is or is not good practice, because environmental performance reports are conflicted and often issued to the client only, inhibiting industry wide feedback mechanisms. Expectations on site also vary wildly with all parties having an EnvCoW, meaning no one really understands what’s expected from each party.
This guidance note offers much-needed clarity and transparency, marking a significant advancement for the sector in by putting responsibility back on the appropriate party and allowing a light to be shone on environmental performance of construction sites.”

Given the increase in unconflicted scrutiny of construction projects in Scotland environmental standards should increase, and those companies that proactively manage their environmental obligations will shine. At Naturally Compliant, we are committed to guiding you through these changes, helping you to navigate the intricacies while keeping your project’s goals and objectives at the forefront. For further information, please do not hesitate to contact Simon Knott.

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