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Speaker 1

The framework that we work with in that if there is surplus government land that it is put to the market

Speaker 2

Yeah

Speaker 1

For disposal. So, I suppose that there was that little bit of conflict - perceived conflict with what we do,
and the policy that exists.

Speaker 2

So, it's probably quite variable, I guess, depending on the politics of the day. But you mentioned that
there's a framework you're working within there, would you say you're more guided by that framework?
Or the the politics of the day when you're making those decisions?

Speaker 1

It is the framework.

Speaker 2

Yeah.

Speaker 1

So the government land transaction guidelines dictate that we are selling government land,

Speaker 2

Okay

Speaker 1

And, or surplus government lands should say,

Speaker 2

Yeah

Speaker 1

So that's what we work - work within. But in terms of what I have to do, but we probably go over, and I
would say that, so we would go over and above, what would be necessary to disclose a part of the
typical government sale of land.

Speaker 2

Why is that?

Speaker 1
I think it's a perception issue.

Overlapping Voice of Speaker 2 with Speaker 1

Speaker 2

You won’t make it to be a communitarian

Speaker 1

So the Kenyan government needs to be seen to be doing the right thing.

Speaker 2

Yeah.

Speaker 1

And, I think what is perceived to be the right thing by government probably needs to be greater than
maybe within private industry.

Speaker 2

Okay. And so that framework that you're working within, has that, does that change with governments?
Does that evolve in response to if you're saying, from hearing and right now, you're saying, there's a
framework, you work within that sometimes you kind of have to do a bit more, or Think a bit here so
that it meets public expectations? So is the framework

Speaker 1

Vary between governments? I think it evolves. But it's evolved. And there's an expectation that, as our
knowledge, particularly around the science of contamination,

Speaker 2

Hmm

Speaker 1

Improves, that there is a greater expectation, and we are seeing an evolution of what's expected to be
done.

Speaker 2

Ok

Speaker 1

So I'd say 15 years ago, groundwater was a significant focus always becoming an increased focus.

Speaker 2

Yeah

Speaker 1
People were, we were then undertaking a greater level of assessment associated with grant law. As we
move forward, groundwater, and soil contamination is an issue. But as part of that, we're now seeing
other parts of land contamination issues evolve, such as soil vapor that 15 years ago, we weren't really
testing too much.

Speaker 2

Okay.

That probably leads nicely. The framework element anyway, into the next question, which is around
what concepts tools and guidance you use to make public decisions. And for some people, it's just a gut
feel there is there isn't anything they use?

Speaker 1

Yeah

Speaker 2

I'm curious to know what you use.

Speaker 1

Yeah. So this is again, another thing that that evolved. And I suppose it goes back to when my position
here was created, that there was no framework, it was so and there was no position. So,

Speaker 2

Yeah

Speaker 1

This position has evolved and developed as I've grown with it. So we've had to, initially it came down to
backfill,

Speaker 2

Yeah

Speaker 1

What, what needs to be done. And then it's now got two appointments, like, you know, we actually
need to come up with a basis for for what we do and when we do it.

Speaker 2

Yeah.

Speaker 1

So from a government land perspective managing contamination, I've developed a contaminated land
management site assessment tool,

Speaker 2
Yeah

Speaker 1

which is pretty much a, it's a, it's a policy document that my group now uses to determine the level of
assessment, assessment that needs to be undertaken for each site.

Speaker 2

Yeah

Speaker 1

And at what point we determine whether a site is suitable for sale, or we need to go back and do some
further work.

Speaker 2

Yeah.

Speaker 1

So release

Speaker 2

Sanatoria came up with about four years ago.

Speaker 1

Yeah, and I think, document I did send on to you. So it's really just a risk assessment tool that we've
used. So I put a little bit of rigor and robustness and it gives us a rather than being a subjective decision,
it comes down to a semi quantifiable assessment of the the risk that that exists outside,

Speaker 2

Instead of feeling like it's got to be more objectivity to it.

Speaker 1

Well, if someone else will had you decide you either remediate this one, but decided not to remediate
that one would say, Well, I went through the risk assessment tool that came out as a level 25. That was
number 20. That was 20

Speaker 2

Yeah

Speaker 1

Points over determined to be a high risk, then we decided that we’d be do rejection

Speaker 2
Presumably, could you help design the tool came up with a tool, you find it works pretty well. Have you
found that, like Marie has had any feedback on it like she finds it? I guess, I'm trying to understand what

Speaker 1

Yeah

Speaker 2

What frameworks help people, what?

Speaker 1

I don't think so. It's based on EPA guidance document.

Speaker 2

Yeah.

Speaker 1

So there's, there's some foundations there that we're relying upon. The development of that

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