Difference Btw EMP and EMS

Impact Assessment and Project Appraisal

ISSN: 1461-5517 (Print) 1471-5465 (Online) Journal homepage: http://www.tandfonline.com/loi/tiap20

Developing environmental management systems to deliver mitigation and protect the EIA process during follow up Dr. Ross Marshall To cite this article: Dr. Ross Marshall (2002) Developing environmental management systems to deliver mitigation and protect the EIA process during follow up, Impact Assessment and Project Appraisal, 20:4, 286-292 To link to this article: http://dx.doi.org/10.3152/147154602781766618

Published online: 20 Feb 2012.

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Impact Assessment and Project Appraisal, volume 20, number 4, December 2002, pages 286–292, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK

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Developing environmental management systems to deliver mitigation and protect the EIA process during follow up Ross Marshall

Developmental projects are dynamic in the manner in which proponents react to issues or events arising during the conceptual planning, design or construction phases. The basic challenge of integrating environmental impact assessment (EIA) into an existing environmental management system (EMS) is to provide adequate control while allowing flexibility to cope with sitespecific project requirements. Environmental management plans (EMP) are one way of controlling the environmental effects of construction projects. These contain project-specific protocols that act as an EMS interface between the EIA and subsequent project planning and development phases. This paper developed from the EIA follow-up session of IAIA 2001 in Cartagena, Columbia outlines the framework for an EMP and its application in respect of the development of an electrical infrastructure project within the UK.

Keywords: environmental impact assessment; environmental management; mitigation; EIA follow up; project management; energy

Dr Ross Marshall is the Environment Planning Manager, SP PowerSystems, ScottishPower, New Alderston House, Dove Wynd, Strathclyde Business Park, Bellshill, ML4 3FF, Scotland; Tel: +44 1698 413273; E-mail: ross.marshall@ SPPowerSystems.com

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N THE FORMAL ASSESSMENT of development acceptability, comprehensive mitigation proposals in an environmental statement (ES) can reduce opposition and assist a developer’s approval process. Good practice presented in the UK’s Department of the Environment, Transport and Region’s (DETR) guidance document recommends that an applicant for development approval clearly outline commitment to the adoption of proposed mitigation measures (DETR, 1997). This is sound advice, but the guide gives little practical advice on how this is to be achieved. As a utility company, with licensed responsibility for maintaining electrical transmission and distribution systems within Scotland, England and Wales, ScottishPower’s PowerSystems division (SP PowerSystems) continually seeks planning consents and licences within these geographic boundaries. There is commercial benefit to SP PowerSystems in being recognised as a clear deliverer of agreed mitigation proposals. Little commercial gain can be expected from reneging on mitigation, if it is likely to result in a lessening in relations between the company and decision-making bodies.

Linking EIA to EMS Business-orientated environmental management systems (EMS) have developed in direct response to increasing internal and external awareness of environmental risk, the need to demonstrate proof that a business is in control of its environmental aspects

Impact Assessment and Project Appraisal December 2002

Developing environmental management systems


and the conditional requirements of the operational licences it holds. Driven by increasing media attention, greater awareness of sustainable development, the need to be ahead of future prescriptive and punitive environmental legislation, reduced public acceptance of pollution and the ever-present threat of liability, most companies have voluntarily developed their EMS in line with the international standards, BS EN ISO 14001 or the European Union’s Eco Management and Audit Scheme (EMAS), or are planning to do so (Marshall et al, 2001). Recently, recognition of the manner in which environmental impact assessment (EIA), mitigation implementation and EIA follow up need to be performed, coupled with a desire to prove mitigation objectiveness and to demonstrate clearly that all planning or consent conditions have been complied with, has encouraged SP PowerSystems to reassess the role of existing EMS systems. Traditionally concerned with the day-to-day running of operational activities, the management controls exerted by the EMS are increasingly being adapted and applied within EIA. Practicalities of bringing EIA into EMS EIA is both an evaluation technique and a regulatory process associated with land-use planning systems. Its methodology follows previously developed national or organisational models. EMS has no statutory basis, representing only a company’s willingness to adopt a system of management that considers and balances environmental aspects. However, EMS do provide systems that track and highlight legislative requirements. While the EIA process is anticipatory in its prediction of adverse effect, the true scale of which can only be monitored after development has occurred, an EMS is reactive, with adverse effect predictions being made on the basis of observed or monitored data. While both systems have the objective of reducing environmental impacts, it may be erroneous to consider the two systems as directly comparable. The ‘scoping’ of key environmental issues and ultimately the decision-making process provides notable case points. In EIA, the scoping process is primarily external with identified aspects being developed through consultation with external organisations, individuals and statutory bodies. In EMS, the

scoping of significant environmental aspects is internal, with the organisation itself determining significance, albeit within the framework of compliance and continual improvement. In EIA, decision-making bodies make decisions concerning the overall environmental acceptability of a proposal, usually after a period of public consultation. Any decisions resulting from the EMS are specific to the business’s objectives and the aims of the organisation controlling the system. In practice, EIA demands management structures to implement the conclusions that arise from its processes. By itself, the EIA process is not equipped to execute such actions. On the other hand, the EMS process is primarily a proactive management tool sensitive to the existing environmental effects of operations and easily adapted to control risk or incorporate enacting procedures. Environmental management plans New developmental projects are ‘dynamic’ in the manner in which planners react to issues or events arising during the conceptual planning, design or construction phases. The basic challenge of integrating EIA into an existing EMS is to provide adequate control while allowing flexibility to cope with the dynamics and requirements of a particular development project. Environmental management plans (EMP) are one way of controlling the environmental effects of construction projects; these contain project-specific protocols that act as an EMS interface between the EIA and subsequent project planning and development phases (Environment Agency, 1999). EIA can identify project specific environmental effects and the need for environmental controls. It would not be practical or necessary to greatly amend the core EMS to provide the necessary controls, as these effects may be short lived, transitory or specific to a particular site affected by development. It would be necessary, however, to create documented links between the core EMS and EIA/EMP procedures. In such situations, project-specific EMP can have a number of benefits. Table 1 shows a simplified model of a projectspecific EMP. The key to its success is the development of strong linkages and practical interfaces between the core EMS and the project-specific EMP.

Table 1. Perceived role and objective of environmental management plans

EIA

Environmental management plans

Construction and operation

Identification of environmental responsibilities for the company and its contractor(s). Predictive and anticipatory processes

→

Setting of project specific objectives and targets during construction (and operation).

→

Reactive operational procedures

Setting of project specific environmental control procedures. In-situ rapid reaction to site conditions or emergencies


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Table 2 expands on these interactions, outlining a more complex model aimed at documenting and controlling the implementation of new development through the existing core EMS. The objective is to execute mitigation or controls identified through EIA or planning consent in accordance with the approach set by the policy and objectives of the core EMS. The project-specific EMP will encompass site operations, the responsibilities of the company and its contractors, specific training requirements and documentation. In seeking to integrate EIA within the overall structure of SP PowerSystems’ EMS, a number of practical issues have required consideration. These are: • Development of procedures setting out the EIA and site/route identification methodologies. • Restructuring existing protocols for EIA. • Clarifying the regulatory structures and decisionmaking strategies that trigger a formal EIA, as opposed to projects where an EIA is undertaken voluntarily. • Development of procedures for formal EIA under specific regulatory or land-use planning systems. • Developing audit trails between the EIA and EMS systems. • Ensuring that the findings of the EIA process are passed directly through to colleagues who are operating in design, construction and ultimately operation. • Developing management links to transfer

Continual improvement is a key element of EMS: organisations that are involved in several similar development projects should be able to show that project EMPs have led to improvements within the core EMS over time

environmental obligations, expectations, consent conditions or mitigation strategies through to contractors involved in construction, infrastructure maintenance or decommissioning projects. • Setting in place structures that link EIA to key performance indicators designed to enhance overall business performance. • Setting up structures that monitor and audit not only performance within EIA, but also its downstream links into construction programmes, regulatory compliance, mitigation performance and verification of residual effect. • Linkage to tenders, contract agreements, the Construction Design and Management (CDM) Regulations 1994, environmental management plans, planning and regulatory consents, and so on.

Table 2. EMP structure and content

Parameter

Information

Introduction

Project description, commitment to mitigation implementation and consent fulfilment during construction phase.

Generic environmental actions

Reference to the standard documents contained within the SP PowerSystems’ ISO14001 EMS relating to construction activities, waste management, control of contractors, and so on.

Environmentally significant changes

The procedure, protocol and consultation process to be followed when environmentally significant changes to the project design are encountered and potential amendments to the EMP are required. Identification of responsibility for overseeing the changes to the EMP and ensuring that these changes do not conflict with any consenting or planning conditions.

Project team roles and responsibilities

The role of the individual project team members is defined. Information should include their name, title, affiliation (that is, staff, contractor or environmental consultant), specific on-site responsibilities, and environmental and auditing duties. The project manager is ultimately responsible for ensuring that the EMP is adequately translated into contract documents and adhered to during all phases of the project.

Liaison and consultation requirements

Details and contact addresses for required liaison between the project team and the relevant external consultees and authorities to ensure that environmental issues are fully resolved.

Consents and permissions

A record of required environmental licences and permissions prior to the start of construction.

Site-specific environmental actions

A table of site-specific environmental actions of significance to the project, that is, mitigation commitments and consenting conditions. Each condition is uniquely identified and grouped chronologically or according to its specific environmental receptor (for instance, nature conservation, noise). The action required is listed. Columns are included to allow for a cross-reference of EMP actions with consent conditions or proposed mitigation actions and with contract document clauses. A column is included for the individual actions to be ‘signed off’ upon successful completion.

Changes during construction

A register of variations records details of changes and environmental implications, linked to a variation document appended to the EMP as a controlled document.

Monitoring programme

Details and schedules of monitoring equipment calibration responsibilities.

Appendices

Variation documents, key contacts, audit schedules and findings, waste management ‘duty of care’ register.

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Continual improvement is a key element of EMS. It is unlikely, given the time-scales of individual development projects, that this could take place. However, organisations that are involved in several similar development projects should be able to show that project EMPs have led to improvements within the core EMS over time.

EIA follow up


In setting linkage between the mitigation proposed and the final consenting conditions, it is on the obligation of the developing party to ensure that: • mitigation proposals such as bunds, landscaping, mounds or drainage systems, are identifiable in plans associated with the planning application; • all physical measures are represented in plans or timetables and are presented at the scale necessary to ensure that mitigation will be effectively achieved; • all relevant mitigation measures are presented and identified as aspects of approval that the developer would be willing to have included in the final consenting documentation; • mitigation proposals material to the application’s acceptance, but which cannot be verified until the onset of further detailed design or on the return of contractors’ tenders, have some form of timetable and consultation with relevant stakeholders to ensure their acceptance as a prerequisite to development progression; and • a management structure is identified to demonstrate what form of follow-up audit or verification procedure is anticipated to ensure that proposed mitigation or consented conditions will be enacted in accordance with the final consent for development or planning permission. In respect of the final bullet point, the following sections of this paper outline the procedural approaches developed by SP PowerSystems in relationship to a transmission project in Scotland (Marshall, 2001).

conductors. On the basis of its experience with the Scottish–Irish Interconnector’s Mitigation Handbook (ScottishPower, 2000), the smaller scale of this project and the recent certification of the company to ISO14001, the company decided to develop an EMP specific to the project proposed. Environmental management plan The EMP system in this, and other construction projects now operating in SP PowerSystems, is dedicated to the project management, monitoring and audit of agreed mitigation strategies, and the verification of predicted environmental effects identified through EIA. The concept of EMP was promoted initially for significant works undertaken on behalf of bodies such as the World Bank (1991). The model for EMP adapted by SP PowerSystems, however, has its origins in a 1999 proposal document promoted by the UK’s Environment Agency for use in their flood defence programme (Environment Agency, 1999). The perceived benefits that SP PowerSystems identifies in EMPs are: • the encouragement of a systematic and explicit approach to the controlled amelioration of environmental effects; • the clear identification of management and contractual responsibilities; • the integration of mitigation measures into the construction programme; • the integration of environmental planning consent conditions into the construction programme; • auditable programmes addressing a key aspect of environmental compliance; • the means of demonstrating compliance with consent conditions by decision-making bodies and other stakeholders; and • a means of engaging stakeholders in constructive dialogue during projects. An added advantage of EMPs is that, for the responsible engineers, they are not prescriptive; allowing the initiative to remain with the project manager, while ensuring that controls are instigated for activities that have the potential for environmental risk, regulatory infringement and overall community relations.

Fife 132 kV system refurbishment Outline framework for SP PowerSystems’ EMPs Project outline and need SP PowerSystems planned to refurbish and upgrade a 132kV transmission system in Northeast Scotland, securing electricity supplies for approximately 160,000 customers over the next 40 years. The scheme involved dismantling 38 kilometres of overhead line, re-conductoring 88 kilometres of overhead line, modernising associated substation equipment and replacing 22 kilometres of overhead line and life-expired towers. Mitigation measures The ES for the project identified significant environmental impacts typically associated with the construction of new overhead systems and the dismantling of old towers and


The EMP is intended to be the interface between the ES and the granting of planning consent for the subsequent engineering project phases such as: • • • •

detailed design; contract documentation; construction; and operation.

The creation of the EMP starts either during the initial phases of a generic construction project or, in the case of the Fife 132 kV refurbishment project, once the mitigation measures or consenting conditions 289


have been identified through EIA or within the planning conditions. The objective of the EMP is to provide a continued link between EIA, consented conditions, the initial environmental appraisal and SP PowerSystem’s environmental policies or initiatives, as well as making explicit to all interested parties the requirement for translation of these findings and polices into contract documents and working strategies. The core information is taken either directly from the ES’s mitigation chapters or the consenting conditions of the final planning consent. This places the EMP in context rather than repeating the full description given in such documents. Table 2 outlines the form and structure of a typical EMP (SP PowerSystems, 1999).


Table of site-specific environmental actions A table of site-specific environmental actions forms the core of the EMP procedures and is the central component of the plan. Depending on the scale of the project, the table of actions may be subdivided into three project phases: before construction; during construction; and following construction. For each phase, a further subdivision by relevant environmental impacts or aspects (such as water quality) is possible. Table 3 presents a template for a typical EMP. A unique numerical identifier references each specific action. For the Fife 132 kV refurbishment project, it was decided to reference also the relevant section numbers within the ES and the planning consent. These references are followed by the objective of the action, which should be one sentence. This information assists the Project Engineer or contractor in understanding the reasons behind each recommendation. It is important that the action statements be clear and concise, but they must be specific enough to ensure the action is adequately translated into contract documents and implemented correctly on site. Responsibility for each action should be clearly assigned to an individual or organisation to ensure implementation. The achievement or verification criteria by which the successful completion of the environmental action can be measured must be clearly stated. Where practical, this target should be measurable, auditable and time-related. Columns in the EMP table are included to allow the design engineer to record the contract references and consent/mitigation references that incorporate each environmental action. This can then be checked by SP PowerSystems’ Project Manager or Environmental Planning Engineer to ensure full inclusion. If the action is not required in contract documents, it has become common practice to shade out the column. A column is available for actions to be signed off as complete by the Resident Engineer or Project Manager after the action has been carried out and

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achievement criterion met. Finally, a column for notes and recommended further actions is provided.

Discussion and conclusions For many companies, EIA now acts as an important pre-construction planning exercise in which design attributes, site and routing strategy, and mitigation concepts are closely examined prior to finalised design and project costing. When moving forward from the planning and consenting phases into the formal construction phase, it is thus important that the design commitments that mitigated environmental effects and assisted in the gaining of consent are carried into practice. For a responsible developer, the follow up of predicted mitigation requirements needs commitment and careful management. The case study presented above demonstrates that mitigation linkage can be achieved through a simple management framework, flexible in design but meeting a variety of anticipated needs. In seeking to formalise and ensure mitigation follow up, EMPs have an important role to play in post-consent and during construction. The EMP system is flexible in its approach to specific forms of development, and has the distinct advantage that, while it forms a component of an ISO140001 certified EMS, it is not so formalised and restricted in its approach to the site-specific issues facing a development project. It is in this area of ‘EMS-lite’ systems that SP PowerSystems now seeks to derive the greatest benefit and control of adverse effects. The company believes that, in seeking mitigation linkage between the EIA and the construction phase, EMPs provide a compact solution that is simple in design and management and complementary to other safety and quality engineering programmes. EMPs also have the advantage that they are compatible with, and integrated within, the wider corporate ISO 14001 environmental management system. Thus, they increase their transparency within an organisation and provide demonstrable proof to regulatory bodies that environmental care has remained a priority within the company’s ethos and governance. In seeking to incorporate a specialist process such as EIA into EMS, it is important to recognise that the systems still have to remain practical, whilst allowing operational control over the project. One of the fascinating aspects of EIA is its flexibility; few other methodologies can be adapted so readily to wide ranging forms of development or perceptions of environmental effect. No company can allow or afford its EMS to stifle such initiative and ingenuity, but equally it is to a company’s advantage to demonstrate through documented controls the decisionmaking processes by which effects were evaluated, mitigated and controlled. Seeking to enhance the practical aspects of EMS



Table 3. SP PowerSystems’ template for the table of site-specific environmental actions with hypothetical entries

No

Objective

Action

Responsible person

Achievement criteria

Contract reference

Consent/ mitigation reference

Completed (initial and date)

Notes further action


Actions during construction Nature conservation To avoid 12 disturbance to moorland

13

Example

Landscape To reduce visual 14 effect at No 27 the Larches Water quality To reduce risk to 15 Middlemarch Burn

No

Objective

Vehicle movement Contractor should be restricted to track or coarse grassland below the moorland Materials and traffic Contractor to be kept off Field A where green orchid resides Planting of Contractor screening belt along Wood Lane during construction Installation of oil protection floating boom

Action

Site engineer

Responsible person

No significant long- Doc 13F/2.3 term damage to moorland

EIS Ref. 3 (sect 6.9)

No evidence Doc 13F/2.4 of transport or material movement

Section 37 Ref. No 3

Material evidence of complete planting scheme

EIS Ref. 6 (sect 11.7)

Photograph of boom in position

Section 37 Ref. No 13

Achievement criteria

Contract Reference

Consent/ mitigation reference

Verification of oil spillage kit presence

Completed (initial and date)

Notes further action

Actions during construction (including monitoring) Recreation and amenity 34 To maintain the privacy of local residents 35

To reduce visual effect at Crudville playing fields

Restricted working hours during weekend

Project manager

No valid outof-hours compliant

ES Ref. 7 (sect 10.3)

Lopping and replanting of trees at Crudville spinney

Contractor

Material evidence of Doc 13F/6.1 completed works

ES Ref. 6 (sect 11.8)


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to control the quality of EIA provides yet another means by which successful companies can lead from the front. EIA is only successful as a management technique when its findings are incorporated into the business-making processes of the company. Successfully integrated within the EMS structures of a company, the findings and conclusions of the EIA can be transferred into action. References


DETR, Department of the Environment, Transport and the Regions (1997), Mitigation Measures in Environmental Statements (HMSO, London). Environment Agency (1999), Environmental Action Plans — Good Practice Guidelines (Anglia Region).

Marshall, R (2001), “Mitigation linkage: EIA follow up through the application of EMPs in transmission construction projects”, paper presented at IAIA ’01 Impact Assessment in the Urban Context, EIA Follow up: Outcomes and Improvements Workshop, 26 May–1 June, Cartagena, Colombia, published on CD-ROM: EIA Follow-up Workshop (Environment Canada, Hull, Canada). Marshall, R, N Smith and R Wright (2001), “A new challenge for industry: integrating EIA within operation EMS”, paper presented at IAIA ’01 Impact Assessment in the Urban Context EIA Follow-up: Outcomes and Improvements Workshop, 26 May–1 June, Cartagena, Columbia, published on CD-ROM, EIA Follow-up Workshop (Environment Canada, Hull Canada). ScottishPower (2000), Scotland– Northern Ireland Interconnector: Construction Conditions Handbook — Coylton Substation, 27% kV Overhead Line and Associated Works (ScottishPower plc). SP PowerSystems (1999), “Construction projects: environmental guidance and construction of an environmental management plan”, ScottishPower, June. World Bank (1991), Annex C — Operational Directive 4.01 — Environmental Assessment (World Bank, Washington DC).

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Difference Btw EMP and EMS

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