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.
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.
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.
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.
- 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)
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.
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
- 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.
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
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