Environmental assessment: a helping hand for EMS?

Despite an unprecedented surge of interest in Environmental Management Systems in the past four years, linkage with other environmental management tools has been slow to develop. David Harrop, Cordah, and EAG Environ's Matthew Davies suggest how a more explicit recognition of the relationship can benefit cost-effectiveness, practice and enable better project-level environmental management.


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Whether in formal schemes, such as ISO 14001 or the EU’s Eco-Management and

Audit Scheme (EMAS), or informal self-certified schemes, the uptake of EMS

has been almost exponential.

The use of EA in business and industry outside of the project planning

process is growing in importance as organisations seek to proactively manage

the environmental consequences of their activities and improve their

environmental performance. The Business Charter for Sustainable Development

(International Chamber of Commerce 1991) includes as one of its 16

principles of environmental management one calling for an EA to be performed “before starting a new activity… and before decommissioning a facility or

leaving a site”.

A number of multinational companies have established their

own policies and operational guidelines for EA, for example Shell

International, and further encouragement has come from the World Business

Council on Sustainable Development, whose business perspective on EA states

that they “can assist companies in their quest for continuous improvement by

identifying ways of maximising profits through reducing waste and

liabilities, raising productivity and demonstrating a compan’s sense of

duty towards its customers and neighbours”.

Many companies seeking to actively demonstrate improvements in environmental performance have, or are

in the process of developing and implementing, an EMS to the requirements of

the international standard ISO 14001. One of the key tasks in the early

stages of developing an EMS is the identification of environmental impacts

and an evaluation of their significance, and this is fundamentally based on

the principles of EA.

EA and EMS compared

EA is predictive, whereas EMS is empirical. The processes, however, do share

requirements:

  • for information on potential project-environment interactions
  • for a systematic approach to information collection and impact assessment
  • to distinguish significant from non-significant impacts.

There is, thus, a logical case to argue for a more explicit linkage between

the assessment of environmental impacts (EA) and their subsequent management

(EMS).

Whilst the details and relative importance of components of EA procedures

differ amongst countries and organisations, there exist a common series of

stages for project-level EA. These begin with a determination of the need

for EA (screening), followed by an analysis of the proposal to establish

what are the main issues for inclusion (scoping). More detailed assessment

then involves the collection and analysis of information (baseline

description and impact prediction and evaluation) and the views and concerns

of stakeholders (public involvement), leading to the production of an

Environmental Statement (ES) describing the nature of the project (and

possibly a range of alternatives), its environmental setting, the impacts

associated with the development, and proposals for dealing with those

impacts considered to be potentially significantly adverse (impact

mitigation). On presentation of the ES to the decision-maker(s), it is

reviewed to check that terms of reference for the project and standards of

acceptable practice have been met (ES review). Finally, there may be

post-project activities in which impacts and environmental management plans

are monitored and audited.

EMS requires an organisation to adopt a programme of continuous

environmental improvement, following a logical sequence of steps (the

commitment to continuous improvement is not a feature of the EMS per se, but

rather a requirement of ISO 14001). These steps include: a strategic review

to identify all the environmental issues affecting the business; defining a

policy and setting objectives and targets to minimise these impacts;

evaluating significant environmental impacts and the aspects of the

organisation and its activities giving rise to the impacts; establishing and

implementing an action programme to achieve the targets set; measuring (i.e.

audit, monitoring etc) performance in achieving the targets; and a periodic

review of the adequacy of the system. As with EA, the core of the process is

the identification and assessment of significant impacts, and the

development and implementation of measures to reduce them.

Information requirements

Inevitably the similarities in the procedures for EA and EMS will result in

common areas of information requirements. The requirements of the EA process

include both project-related and environmental information and data. The

information requirements increase as the EA process develops:

  • Screening ­ requires basic information on the project and its

    environmental setting in order to determine whether the proposals are likely

    to give rise to environmental impacts of sufficient significance that EA is

    warranted

  • Scoping ­ requires further information on the project to identify the main

    areas of potential impact, and, in turn, the key issues and sensitivities on

    which the subsequent EA should focus

  • Impact identification, prediction, mitigation and assessment ­ principal

    core information needs include a project description; process information

    and information on the quality, uniqueness and vulnerability of

    receiving/surrounding environmental media and resources.

For the environmental management of an organisation the core information

needs essentially relate to the company’s/organisation’s activities and the

nature of the surrounding environment. These needs include data on pollutant

emissions, waste generation, raw material consumption, energy and water use,

noise and vibration, land use, transport generation and vehicle emissions

and finally data on surrounding environmental quality (air quality, water

quality, ecological resources, land uses etc) to put the effects of the

company into context. As with EA, the information needs increase in scope

and detail as the process of impact identification and evaluation develops:

  • The initial review ­ considers the main interactions between the ‘project’

    and the environment

  • The environmental impact evaluation ­ identifies the main impacts on the

    basis of a systematic examination of aspects and the environment and

    develops criteria for the subsequent assessment of impacts and the selection

    of those considered ‘significant’

  • The ES ­ publicly available document setting out the organisation’s

    assessment of its environmental effects and the information against which to

    measure improvements in environmental performance (only in the case of EMS

    developed to EMAS ­ organisations may, however, publish a report on their

    environmental performance)

Linking the tools

Common EA and EMS information needs and similarities in procedural steps

provide a strong argument to link the two processes to provide a more

effective environmental management tool. For new developments or businesses

the EA can set the framework for the subsequent development of an EMS. For

organisations with an established EMS, the system should include

arrangements for the prior assessment of new projects, and accommodate the

possible need for the assessment process to meet regulatory requirements.

The linkage of EA and EMS will offer benefits to environmental management

practices. The principal benefits will include:

  • Cost-effectiveness, by avoiding the need to reinvent the wheel in

    collecting and analysing environmental performance data

  • Through EA the collection of baseline information and, where appropriate,

    on-going baseline monitoring provides the data stream against which

    subsequent operational performance can be measured at the EMS stage

  • The linkage will extend the process of project design into the

    commissioning phase by being able to measure/monitor performance on an

    on-going basis, facilitating on-going refinement

  • The linkage will advance the practice of EA by informing the utility of

    predictive techniques and the effectiveness of mitigation interventions

  • Setting the EMS in the context of a public and transparent process will

    add credibility and allow subsequent public disclosure on environmental

    performance.

Barriers and strategies

The main barriers to linking the EA and EMS processes are largely a function of current management and

practice, rather than a fundamental inconsistency between the two processes.

An analysis of current practice reveals the following:

  • Changes in project scope between development and eventual construction and

    operation often limit the applicability of information and analysis made as

    part of the EA to later EMS

  • Considerable time lags between the completion of the EA and the

    commissioning of the project

  • Ownership of the two processes often lie in different parts of the

    organisation; EA with new projects/pre-commissioning teams; EMS with

    facility management

Understanding these barriers is the first step in developing strategies to

link the two processes. More effective linkage could be encouraged through:

  • Focusing base-line data collection/monitoring on variables which offer

    utility as future performance indicators

  • Developing mitigation strategies that can be tracked, audited and

    reviewed

  • Including post-project analysis of predictive accuracy and mitigation

    implementation as a formal stage of EA

  • Planning for the allocation of resources and management responsibility to

    link the processes over the life cycle of a project, rather than as

    separate, stand-alone activities at different stages in the project life

    cycle.

For projects where the need for assessment has been recognised and

initiated from within an EMS, the EA should refer to the EMS’s existing

arrangements for the control of the identified impacts in the mitigation

measures. Similarly, the mitigation measures should propose amendments to

existing arrangements to accommodate the needs of the new project.

Linking the two processes will encourage a broader role for EA, informing

not only project design, but also process efficiency and product design. A

combined EA- EMS process will provide a powerful management tool for

organisations seeking to identify and implement sustainable and

eco-efficient strategies.

Similarities

Systematic approach

Identification and quantification of interactions between a project and the

environment

Prediction of future impacts

Assessment of impact significance

Identification of environmental performance indicators

Identification of remedial measures for significant impacts

Management intervention to reduce significant impact

Prediction of the effectiveness of mitigation measures

Need for post-project audit and review

Differences

EA tends to rely on accepted thresholds and criteria for deciding

significance whereas general EMS criteria tends to be self selected

depending on the organisation or sit

EMS focuses on continuous improvement

EA always results in the preparation of a public document whereas EMS often

does, but publication is not mandatory

© Faversham House Ltd 2022 edie news articles may be copied or forwarded for individual use only. No other reproduction or distribution is permitted without prior written consent.

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