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