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The EPA is currently progressing the development of new guidance for brownfield soil and stone by-product material, including the introduction of a proposed PFAS (“forever chemicals”) screening framework and new pollutant limit values (PLVs) for the reuse of soil and stone under Article 27. The consultation is of significant importance to the construction and housing sectors, particularly in the context of urban regeneration, apartment delivery, major infrastructure projects and circular economy objectives.
The proposed framework could materially affect the reuse, treatment and disposal of excavated material arising from brownfield development sites. CIF has therefore prepared a detailed technical submission on behalf of members broadly supporting the EPA’s objective of improving environmental protection and regulatory clarity, while seeking a more proportionate, risk-based and operationally workable framework before implementation.
Key themes within the CIF submission include the need for greater scientific transparency around the derivation of proposed pollutant and PFAS thresholds, retention of site-specific risk assessment pathways rather than rigid pass/fail criteria, assessment of laboratory and EPA operational capacity, and national piloting before rollout. CIF has also highlighted the potential implications for housing viability, landfill capacity, infrastructure delivery and the future management of non-greenfield soil and stone.
The EPA has indicated that the current consultation represents an initial stage in the process. Further consultation on the first draft guidance document is expected to take place over the summer months, followed by development of a revised draft guidance document. The EPA’s current timeline indicates that the final document is expected to be submitted to the EPA Board for approval in September 2026 prior to publication.