ESCP Submission in Singapore: The PUB ECM Plan Process

In Singapore, an Erosion and Sediment Control Plan (ESCP) is submitted to PUB as an Earth Control Measures (ECM) plan. It is designed and endorsed by a Qualified Erosion Control Professional (QECP), and it must be approved or cleared before earthworks begin. This guide sets out who must submit, what the plan must contain, how the submission is made, and what the site team must do once the plan is approved.

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TL;DR

The Singapore term for an ESCP is the ECM plan, governed by PUB’s Code of Practice on Surface Water Drainage.
A QECP must design and endorse the plan, and PUB approval or clearance is required before any earthwork starts.
Smaller works may qualify for the self-declaration route, filed through the BPU Qualified Persons Portal with Singpass.
Approval is the start of the obligation: inspection, QECP audits, discharge monitoring and CCTV apply throughout construction.

What an ESCP is called in Singapore
Who must submit and who may prepare the plan
What the ECM plan must contain
Drawing requirements
How the submission is made
Preparing a submission that clears first time
Obligations once the plan is approved
ECM compliance and Design for Safety
Perspective
Support with ECM and authority submissions
FAQ
Sources

What an ESCP is called in Singapore

Searches for an “ESCP submission” usually refer to what PUB, Singapore’s national water agency, calls the Earth Control Measures plan. The requirements are stipulated under PUB’s Code of Practice on Surface Water Drainage, and the same document sets the discharge limits that the plan is designed to meet.

The rationale is geographic. PUB notes that two-thirds of Singapore’s land area is water catchment, so silty discharge from construction sites can reach waterways and reservoirs. The ECM plan is the instrument that controls this at source: it limits exposed bare earth and treats site runoff before it leaves the boundary.

Since 2007, the Code has required contractors to implement ECM best practices at worksites and to submit an ECM plan to PUB, designed and endorsed by a QECP, before any construction work starts. Related background on the measures themselves is available in the firm’s guide to erosion control measures in Singapore.

Who must submit and who may prepare the plan

The duty falls on the site operator or contractor. Under Clause 6.3.3 of the Code, a QECP must be engaged to design a comprehensive ECM plan for PUB’s approval, and adequate ECM must be implemented before the commencement of any earthwork.

A QECP is a professional engineer registered under the Institution of Engineers, Singapore (IES), engaged by the developer or contractor to design the ECM and check its implementation on site, as PUB describes the role. The QECP therefore carries two responsibilities: design at the submission stage and supervision of implementation afterwards.

Other agencies reinforce the requirement for their own projects. For works under the Land Transport Authority, LTA requires the contractor to have the ECM plan endorsed by a QECP, submit it and obtain a Clearance Certificate from PUB, implement ECM accurately, and place a full-time site staff member with an Earth Control Measures Officer (ECMO) qualification on sites larger than 0.5 hectares.

The QECP’s role sits alongside the Qualified Person’s statutory duties. The distinction is explained in the firm’s note on QP and PE roles and its overview of Qualified Person duties.

What the ECM plan must contain

PUB’s ECM Submission Guidelines (October 2022) set out the content of the report. It must include:

A brief project introduction.
The construction sequence.
Sub-catchment calculations for storage ponds.
Holding-pond and cut-off-drain capacity.
TSS-yield calculations before and after erosion control.
A summary table.
An inspection, monitoring, maintenance and review plan.

The design standard is set in Clause 6.3.5 of the Code: the ECM must cope with at least a storm of 5-year return period. Discharge into the storm water drainage system must not exceed the TSS concentrations prescribed under Regulation 4(1) of the Sewerage and Drainage (Surface Water Drainage) Regulations, as stated in Clause 6.3.1 of the same document.

Erosion control and sediment control

PUB’s sample specifications divide the measures into two parts.

Plan component	Typical measures named by PUB
Erosion Control Plan	Minimising bare earth areas, slopes and stockpiles through sequencing and phasing of earthworks; paving or covering bare earth surfaces
Sediment Control Plan	Concrete-lined cut-off drains (minimum C7 precast channel), sealed site hoarding, ramp or curb at site entrance and exit, separate drainage for bare and non-bare earth, silt fences, silt traps, holding sumps or ponds, silty water treatment systems, turbidity curtains for works in or beside water bodies

The submission checklist

The ECM Submission Checklist requires the QECP to confirm that the plan covers, among other items:

project background and description, and design calculations;
a runoff coefficient of 0.65 or higher;
a to-scale ECM drawing, location plan and topographic plan;
boundary hoarding with a sealed footing;
total holding and storage capacity, and exposed and covered areas;
separate drainage systems for clean and silty runoff, with catchment and flow direction;
cut-off drains, holding ponds, treatment plants and discharge outlets with dimensions;
a copy of the valid QECP licence.

Drawing requirements

The ECM site plan is where many first submissions are queried. Under the Submission Guidelines, the drawing must show at least two road or street names and at least five spot levels in SHD to indicate the terrain profile, with one level near the holding pond. It must be submitted in colour and duly endorsed by the QECP.

The drawing should be consistent with the wider drainage submission for the same site. The firm’s notes on PUB drainage design submission requirements and on drainage systems and their components cover that interface.

How the submission is made

The contractor submits the QECP-endorsed plan to the Director, Catchment and Waterways at PUB, in the prescribed format, to obtain clearance before earthworks start, as the sample specifications state. The firm’s own walkthrough is in its Earth Control Measures submission guide.

The self-declaration route

PUB’s ECM Self-Declaration Scheme (Phase 3, updated 1 December 2023 and effective 1 January 2024) permits self-declared proposals for:

development works with a total site area of 0.5 ha or less;
linear works with a maximum exposed area of 0.2 ha or less;
carpark improvement works;
drainage works up to 2 m wide and 40 m long.

Self-declared proposals go through the BPU Qualified Persons Portal using Singpass. Self-declaration does not remove accountability: QECPs and contractors remain responsible for effective ECM design and implementation, and PUB may rescind approvals and take enforcement action for non-compliance.

Review times

PUB’s Service Commitment gives a typical response time of 14 working days for Development Control, Detailed Plan, and Clearance for TOP/CSC, and 1 working day for Simplified Submission. Programmes should allow for this period, plus time for any revision, before the earthworks start date.

Preparing a submission that clears first time

Confirm the route. Compare site area and works type against the self-declaration criteria before deciding between self-declaration and a full submission.
Engage the QECP early. The plan depends on the construction sequence, so the QECP should see the earthworks programme before the design is fixed.
Settle the geotechnical picture. Soil conditions influence storage sizing and treatment. The firm’s guides on geotechnical investigations and geotechnical analysis explain the inputs.
Check the report against the checklist. Calculations, runoff coefficient, capacities and the licence copy should all be present before filing.
Check the drawing. Colour, scale, road names, five SHD spot levels and QECP endorsement are the usual points.
Coordinate with other approvals. Excavation and foundation works often carry their own requirements, covered in the notes on deep excavation approval and piling permits.

Obligations once the plan is approved

Approval triggers the operating duties. Clause 6.3.8 and related provisions of the Code require the project team to:

implement the ECM according to the endorsed plans before earthworks start;
inspect the ECM regularly and during or after every rain event;
arrange for the QECP to audit or review every stage of the earthworks and construction works;
revise the ECM on site according to the QECP’s advice;
maintain the measures, including replacing silt fences and erosion control blankets, re-paving worn surfaces, removing silt from drains and holding ponds, and removing sludge from the treatment plant;
monitor discharge water quality and keep CCTV systems operational and linked to the Silt Imagery Detection System (SIDS), responding promptly to alerts;
keep inspection, audit and review reports on site for PUB;
not remove the ECM before completion, and inform PUB before removal.

The ECM site audit inspection form, with photos and a site plan, must be submitted within two weeks of the QECP and builder site audit.

For monitoring, all construction sites of 0.2 hectares and above must install CCTV on treated water discharge into public drains, with the feed analysed in real time and alerts sent to parties such as the Project Manager or ECMO. PUB also encourages treatment systems with an auto-intervention feature that halts operation when discharge exceeds 50 mg/L of TSS.

The plan is not static. LTA’s guidance describes the ECM plan as a dynamic document that should be reviewed as site conditions change, with modifications documented. Changes to the sequence tend to follow site clearance, since removing vegetation exposes more bare soil; planning for tree removal for land development at the start of the programme helps keep the exposed area consistent with the endorsed plan. Typical causes of site failures are covered in the firm’s earthworks failure guide.

ECM compliance and Design for Safety

The ECM plan sits within a wider compliance picture. The WSH (Design for Safety) Regulations 2015 apply to developer projects involving construction work with a contract sum of $10 million or more and development under section 3(1) of the Planning Act. Earthworks sequencing, slope exposure and temporary works are design decisions that affect both safety and erosion control, so the two workstreams benefit from coordination.

Penalties under the WSH Act are significant. MOM lists a maximum fine of $500,000 for a corporate body’s first conviction and $1 million for a repeat offence. For individuals, the first conviction carries up to $200,000 and/or two years’ imprisonment. Non-compliance with a Stop Work Order attracts a maximum fine of $500,000 plus $20,000 for each day the offence continues, with potential imprisonment of up to 12 months. These apply to the WSH regime and are separate from PUB’s own enforcement powers over ECM approvals.

Perspective

Most delays we see on ECM submissions come from sequencing, not from drainage arithmetic. When the construction programme and the ECM plan are prepared separately, the phasing shown to PUB no longer matches what the site intends to do, and the plan has to be reworked.

Our approach is to treat the ECM plan as part of the engineering design package. Structural, geotechnical and authority submission work is handled together, so the earthworks sequence, the temporary works and the erosion control layout are consistent from the first drawing.

We also treat approval as the midpoint. A plan that is endorsed but poorly maintained exposes the contractor to PUB action, so we emphasise inspection routines, QECP audits and prompt revision. Our aim is timely, clearly communicated submissions that project teams can rely on.

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Support with ECM and authority submissions

AECTechnicalSG provides engineering design, PE endorsements and statutory authority submissions for developers, contractors, architects and building owners in Singapore, including submissions to PUB, BCA, URA, SCDF, JTC, LTA and NEA. Project teams preparing earthworks can review the full range of engineering and submission services or discuss a specific submission through the AECTechnicalSG website.

Temporary works design and PE endorsement are available through the PE endorsement and authority submissions page, which suits projects where the ECM plan must align with excavation support and other temporary structures.

FAQ

Is an ESCP the same as an ECM plan in Singapore?

In practice, yes. The plan that PUB reviews is the Earth Control Measures plan, which covers erosion control and sediment control for the site. It is designed and endorsed by a QECP under the Code of Practice on Surface Water Drainage.

Who endorses the plan?

A QECP, who is a professional engineer registered under the IES and engaged by the developer or contractor. The QECP designs the ECM and checks its implementation on site, and a copy of the valid QECP licence is part of the submission checklist.

Can a small site self-declare?

Possibly. Under Phase 3 of the Self-Declaration Scheme, development works of 0.5 ha or less, linear works with exposed area of 0.2 ha or less, carpark improvement works and small drainage works can be self-declared through the BPU Qualified Persons Portal. Responsibility for effective design and implementation stays with the QECP and contractor.

How long does PUB take to respond?

PUB’s Service Commitment states a typical 14 working days for Development Control, Detailed Plan, and Clearance for TOP/CSC, and 1 working day for Simplified Submission. The current commitment should be confirmed on PUB’s page when programming.

Does CCTV monitoring apply to every site?

It applies to construction sites of 0.2 hectares and above, which must monitor treated discharge into public drains with real-time alerts. The ECM plan itself must describe the monitoring and alert arrangements.