eia-ems

January 28, 2008 15:18 WSPC/154-JEAPM 00286

Journal of Environmental Assessment Policy and ManagementVol. 9, No. 4 (December 2007) pp. 385–397© Imperial College Press

AN ALTERNATING-SEQUENCE CONCEPTUALFRAMEWORK FOR EIA-EMS INTEGRATION

ANASTÁSSIOS PERDICOÚLIS

Department of Biological and Environmental EngineeringUniversity of Trás-os-Montes and Alto Douro

Vila Real 5001-801, [email protected]

BRIDGET DURNING

Oxford Institute for Sustainable DevelopmentSchool of the Built Environment

Oxford Brookes UniversityGipsy Lane, Oxford OX3 0BP, United Kingdom

[email protected]

Received 31 May 2006Revised 5 October 2007

Accepted 8 November 2007

The integration of Environmental Impact Assessment (EIA) and Environmental Manage-ment Systems (EMS) has been approached several times in recent years. This article reviewsexisting conceptual frameworks and specific issues regarding the EIA-EMS integration, andrecommends a new conceptual framework which is based on an alternating sequence of EMSand EIA. It also proposes adaptations in key documents of both processes. The recommen-dations are adaptable to the varied practice of EIA across the globe, and conform to theISO14001-compliant EMS protocol.

Keywords: Environmental Management Systems (EMS); Environmental Impact Assess-ment (EIA); process; integration; conceptual framework; documents.

Introduction

The integration of Environmental Impact Assessment (EIA) and EnvironmentalManagement Systems (EMS) has been approached several times in recent academicliterature, and most indications about its feasibility are favourable and encouraging.This article reviews existing conceptual frameworks and individual issues raisedin the literature regarding the integration and, based on them, recommends a new

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conceptual framework. It also identifies appropriate modifications which would beneeded in key documents of the two processes in order for this integration to becomeoperational. In order to cover all, or realistically most of the varied EIA practiceacross the globe, the article maintains a general and abstract character.

The readership of the article is considered to be methodologists and practitionersof EIA and EMS. It is structured as follows: introduction, overview, analytic presen-tation of the state-of-the-art in EIA-EMS integration, new conceptual framework,discussion, and conclusions.

Overview

EIA and EMS are both concerned with the environmental effects of developmentprojects, although they came into existence from different origins. The two processesalso currently have different legal and standardisation status (Eccleston and Smythe,2002).

Since the 1999 International Association for Impact Assessment (IAIA) confer-ence in Scotland, the link between EIA and EMS has received certain attention in theacademic literature (Sheate, 1999). Consideration of this particular link, togetherwith that of other “environmental” tools, has also been encouraged to a certainextent through workshops in subsequent IAIA conferences — e.g., 2002, in TheNetherlands (Sheate, 2002).

A number of researchers in published work provide general points of encour-agement, or even more concrete contributions, towards the integration of EIA andEMS. For example, Barnes and Lemon (1999) provide a successful example ofan EIA-EMS link from the early 1990s — i.e., before the publication of the firstinternational EMS standard, ISO 14001:1996. Their case study included produc-tion of an Environmental Management Plan (EMP), which is prepared at the sametime as EIA and intended to address the mitigation measures required for theconstruction and operation stages of the project. Barnes and Lemon propose thatone of the benefits of the combined practice is the production of a more detailedEnvironmental Impact Statement (EIS) with combined environmental managementinformation. Furthermore, they suggest as further benefits that the EIA-EMS inte-gration allows the EIA process to focus on critical environmental aspects and solu-tions while the EMS can focus on more detailed and technical issues (e.g., dustsuppression).

Also at an “early” stage in the literature, but shortly after the publication ofthe ISO 14001:1996 standard and looking at the benefit of EIA to EMS devel-opment, Ridgway (1999) identified that the non user-friendly format of EISs (theEIA report) does not readily assist in the development of EMSs for the subse-quent operational phase of a development. In particular, the all-important (to the


An Alternating-Sequence Conceptual Framework for EIA-EMS Integration 387

EMS) mitigation recommendations (e.g., design, management, monitoring) may bedifficult to implement due to overwhelming aggregation and lack of proper summaryor highlighting.

More recent literature has seen a number of approaches for integration beingput forward. Nitz and Brown (2002) suggest a simplification in “environmentalmanagement tools” — a general category that includes both EIA and EMS — isneeded, preferably grouped by objectives. In this case, EIA and EMS would fittogether under “impact management” or a similar objective.

Eccleston and Smythe (2002) highlight the potential advantages of the integra-tion and outline a general conceptual framework for the purpose, with EIA leadingin the first phases of the project, and EMS leading in the later operational, phases.

Sánchez and Hacking (2002) present another approach to linking EIA and EMS,which originates from an apparent shortcoming of the EIA process: the failure toimplement mitigation measures or monitor environmental impacts following theapproval of projects. These aspects are beyond EIA jurisdiction, but also disre-garded by subsequent EMS application. A key feature of their approach is that itdeals specifically with environmental aspects, which is a fundamental and exclusivenotion of EMS.

Ridgway (2005) continues by pointing out the need for an orderly EIS presenta-tion, and suggests the need for a clear identification and “tagging” of commitmentsin the EIS document, as well as the transformation of the EIS from a “record” (i.e.,static document) into a dynamic (i.e., updateable) EMS (termed “the environmentalmanagement program”).

Morrison-Saunders and Arts (2005) come from the point of view of EIA follow-up (i.e., “the monitoring and evaluation of the impacts of a project or plan (thathas been subject to EIA) for management of, and communication about, the envi-ronmental performance of that project or plan” — Morrison-Saunders and Arts,2004, as quoted in Marshall et al., 2005), and are in principle opening up linkingEIA with management instruments (e.g., EMS) by arguing that the emphasis of EIAfollow-up must be on achieving sound management outcomes.

Broderick and Durning (2006), echoing the work of Barnes and Lemon (1999)report that the use of Environmental Management Plans (EMP) is increasinglytending to supplement and be integrated into EISs in the UK, even though theirscope and use is often restricted to the project’s implementation phase. The EMP isprepared under the auspices of the project proponent, but returns valuable benefitsin the successful implementation of the project.

Despite the pro-integration spirit documented in the relevant literature, someresistance is also apparent regarding the integration of EIA-EMS and other sim-ilar “environmental tools”. This resistance is attributed mainly to caution (Scraseand Sheate, 2002) or disciplinary interests (Sheate, 2000), but may take the form



of competition over domains or duplication of tasks (Vanclay, 2004). RegardingEIA-EMS integration in particular, Sánchez and Hacking (2002) report the obsta-cles to integration as being: insufficient interaction between the EIA and proponentteams; independent EIA and EMS consultancy services; the image of EIA as merelybureaucratic, and the focus of EIA concerns merely on obtaining a favourable deci-sion — i.e., approval.

State-of-the-Art

The most significant contributions concerning EIA-EMS integration come from fewarticles (Eccleston and Smythe, 2002; Sánchez and Hacking, 2002; Ridgway, 1999and 2005). Their approaches are presented in more detail in the following section.The contributions are made at two levels: a higher, conceptual level, and a lower,specific issue-focused level.

Approaches

Relevent literature reveals three approaches to EIA-EMS integration, althoughwhilst the Eccleston and Smythe (2002) approach is a proper conceptual frame-work, the other two contributions (Sánchez and Hacking, 2002; Ridgway, 1999 and2005) merely offer ideas about possible link configurations and tools.

Eccleston and Smythe (2002) propose a single-sequence conceptual frameworkfor the EIA-EMS integration (Fig. 1), in which EIA is leading in the first phasesand EMS is leading in the later phases.

Sánchez and Hacking (2002) offer another single-sequence idea for the EIA-EMS integration (Fig. 2), quite similar to the Eccleston and Smythe proposal.

Ridgway presents a set of generic phases for projects, for which various environ-mental tools are identified (Ridgway, 1999). Thus, EIA and EMS are encountered asprotagonists in different phases of the project life (Fig. 3). Although it is not meantto be a conceptual framework for EIA-EMS integration, the scheme indicates apossible alternating sequence of “environmental tools” — e.g., EIA-EMS-EIA.

Specific issues

Besides the higher-level conceptual frameworks detailed in the literature, the keyarticles also reveal a number of medium- to low-level specific issues that areless abstract and which help to refine the perspective of EIA-EMS integration.These are:

(i) Environmental aspects are an exclusive feature of EMS, even though thenotion itself is not presented very clearly in the ISO 14001 standard (ISO,2004). Sánchez and Hacking (2002) interpret environmental aspects as the



Fig. 1. Eccleston and Smythe’s single-sequence conceptual framework for the EIA-EMS integration;adapted from Eccleston and Smythe (2002).

“causal mechanism” that stands between the action (cause) and end result(effects, change, or impact), which hints to a relatively easy link with theEIA practice.

(ii) The static and rather non-clear presentation nature of EISs does not providea natural link with the EMS documents (Ridgway, 2005), which hints to thenecessity for transformation work in the EIS construction and format.

(iii) The significance of impacts is treated differently in the two processes: explicitlyin EIA, and vaguely in the ISO 14001 EMS standard (Eccleston and Smythe,2002). This is a particularly low-level issue, but uniformity is important forthe process integration.

(iv) The varied (i.e., non-standard) EIA process methodology contrasts with thestandards of EMS (ISO, 2004; EC, 2001). Besides the high-level issue of the



Fig. 2. Sánchez and Hacking’s single-sequence idea for the EIA-EMS integration; based on Sánchezand Hacking (2002) highlighting the EMS structure.

Fig. 3. Ridgway’s project phases and main environmental tools; adapted from Ridgway (1999).



conceptual framework treated in this article, this contrast may give rise tolower-level issues such as non-uniformity in notions and terminology.

(v) The legal status of the two processes is different: EMS is a voluntary scheme,while EIA is a legal requirement is many countries. The lack of a common legalstatus is a higher-level issue of compatibility, as common status would givemore stability and credibility to the integration. In addition, the legal statusissue extends to more detailed procedural issues, such as the environmentalcompliance requirement (Eccleston and Smythe, 2002).

(vi) The in-house versus consultant-based process of execution interferes with theintegration and has been identified as a hindering factor (Sánchez and Hacking,2002).

(vii) Several other process steps, such as scoping, impact assessment, and publicparticipation, are treated only in EIA but could also benefit the EMS practice(Eccleston and Smythe, 2002).

A New Conceptual Framework

Based on the literature and our own understanding and experiences of the two pro-cesses, we propose a new conceptual framework for EIA-EMS integration. Whilsttheoretical, the framework is designed to be compatible with the varied practiceof EIA, and the ISO 14001:2004 standard of EMS (ISO, 2004) — or the equiva-lent part of the EMAS standard (EC, 2001). The level of detail in the frameworkis deliberately set at an abstract or high-medium level. Due to the broad diversityof the EIA practice worldwide, we do not consider it would be beneficial to makerecommendations at a more detailed level at this theoretical stage.

Framework

The new conceptual framework which harmonises the sequence of responsibilitiesbetween the EIA and EMS processes is presented in Fig. 4 and features an alternatingsequence of EIA and EMS steps.

Starting with EMS, and specifically with the environmental policy, the frame-work gives a “top-down” character to the process. It begins with the project proposal(with detailed specifications) being drafted during the planning phase in accordancewith the environmental policy.

The switch to EIA occurs when the project proposal, incorporating an envi-ronmental management programme for each phase of the project, is completed.This extended project proposal is then subject to the EIA process more-or-less as itcurrently exists, until a decision is obtained from the authorities.

A switch-back to EMS occurs with the approval of the project proposal (incor-porating the environmental management programme), which can subsequently be



Fig. 4. The proposed alternating-sequence conceptual framework for the EIA-EMS integration, withkey documents of both processes.

developed into a proper EMS. The process then loops into the continuous improve-ment circle (ISO, 2004) of an operational EMS.

As suggested in the framework derived from Ridgway contained in Fig. 3, thedecommissioning phase of the project would be the jurisdiction of the EIA process,



so a return to EIA can be also added to our conceptual framework for when theproject has reached the end of its lifetime.

Finally, although this is not shown in the conceptual framework in Fig. 4, aseparate loop back to EIA would provide feedback to the EIA team regarding theirimpact forecasting capabilities, which provides the possibility for improvement infuture applications.

Document modifications

In order for this framework for EIA-EMS integration to be implemented, somemodifications in the role and/or content of key documents of both processes wouldbe needed. For reasons cited previously due to variation in EIA practice these aredescribed at a medium level of detail:

(a) The initial environmental review (ISO, 2004; Cagno et al., 1999) wouldserve as a precursor of the baseline study of the EIS (hereby called “impactstatement”).

(b) The project proposal, usually prepared before the EIA begins, would include anexecutable environmental management programme for all phases of the project,as per EMS specifications.

(c) The impact statement would pay due attention to all phases, and include anaspects analysis to bridge with EMS.

(d) The decision or approval of the project proposal would include summaries ofthe environmental management programme — eventually with modifications.

(e) The EMS documents, in addition to their main role, would also feed back intothe EIA team’s knowledge-base and know-how.

Discussion

Implications

Our framework would have a number of consequences for how both the EIA andEMS processes are undertaken. For EIA, the recommendations presented in theprevious section imply the following consequences:

(a) the project proposal will have to follow a proper and formal environmentalpolicy and planning procedure, as per EMS specifications;

(b) the project proposal will contain a management programme for all projectphases;

(c) the impact assessment will include environmental aspects analysis (Sánchezand Hacking, 2002), and will give due importance to all phases of the project;

(d) the decision/approval will end up with a complete document, out of which anEMS could be readily established;



(e) after some time of the project operation, the EMS could feed back into the EIAteam about the real environmental impacts; thus, the EIA team could improveits impact forecasting precision.

For EMS, the recommendations presented in the previous section imply thefollowing consequences for the process:

(a) the first two phases, environmental policy and planning, would be as in anyEMS process, except there is no project in operation yet (it would have tobe hypothesised or drafted based on experience of similar operations with thesector);

(b) the next two phases following EMS planning would be the “EIA module”;(c) following the successful conclusion of the “EIA module”, implementation (of

the project and the environmental policy) and operation occur;(d) after the first full EMS cycle of implementation-audit-review, the “EIA module”

would not be necessary in any continuing cycles, and the EMS would proceedsnormally throughout the operation phase;

(e) decommissioning would be considered in both the EMS-EIA documentation atthe terminal phase of the project.

Beyond the technical changes that an EIA-EMS integration framework impliesfor each one of the two processes, it also has implications for both through the waypeople think and work. Effective collaboration is essential to resolve at least twoof the main obstacles to integration, (as reported by Sánchez and Hacking, 2002)i.e., the interaction between the EIA and proponent teams, and between the EIAand EMS consultancy services. The success of such collaborations is not likely tobe directly dependent on the regulations or standards, but rather to people’s visionand will.

Global assessment

By alternating the steps of the two processes in an A-B-A(-B) model, the proposedframework would bring a closer collaboration between the professionals involvedin implanting EIA and EMS. Simpler links of the A-B type are likely to supportmore superficial relationships, with “finish and exit” attitudes.

The inter-twining of the tasks between the two processes also gives a moreuniform approach to environmental impacts of projects, dealing with them in a singleframework before, during, and after the development. Eventually, the alternating-sequence framework may be capable of producing a proper thinking and integratedattitude about environmental impacts, instead of maintaining separate treatment bydifferent professionals (of EIA and EMS, to mention the least).



Technical assessment

Some technical innovations of the framework invite some reflections. To beginwith, the initial environmental review (IER) is given a new role and responsibil-ity, namely to serve as a precursor of the baseline study of the impact statement.The baseline study of the impact statement should then be in accordance withthe IER. This new role of the IER also implies a flexible scope: site-specific butwith extensibility to wider issues approached in EIA (e.g., cumulative effects, sus-tainability indicators). Finally, the IER also provides an opportunity to introduceenvironmental aspects and define the way that they will be used later in the impactstatement.

Major innovations in the impact statement include environmental aspects andthe environmental management programme (EMPg). Such provisions are capableof improving the image of EISs as non-user friendly and bureaucratic documents,as well as being non-usable in EMS (see, for instance, Ridgway, 1999 and Sánchezand Hacking, 2002). Technical solutions to the above innovations are expected to begiven in case-by-case applications, recruiting the capacity and experience of bothEIA and EMS professionals.

Future work

The next step following the conceptual framework is its experimental implementa-tion. Resolution of the specific issues rests with the EIA and EMS practitioners, inper-country application cases. Reflections on more general methodological issues,and potentially refinement of the framework, will be possible only after collectiveexperience of several applications.

Conclusions

With respect to the integration of EIA with EMS, the new alternating-sequenceconceptual framework, EMS-EIA-EMS(-EIA) presented in this article, providesa balanced division of tasks. This framework includes a series of modificationsto key documents of both processes, to render them appropriate for smoothintegration.

Institutional issues of the EIA-EMS integration, such as a common legal statusof both processes, appear to be the object of national deliberations. Methodological(or technical) issues of the EIA-EMS integration, such as the environmental aspects,can be (and are being) treated at a more detailed level of attention by the scientificcommunity. The most important of these specific issues have been identified, andfuture research is likely to give satisfactory answers.



Acknowledgements

In the preparation of this article, the first author wishes to express his gratitude tothe Fundação para a Ciência e Tecnologia (FCT) of the Portuguese government fortheir financial support to his 2005–2006 sabbatical leave, and to the School of theBuilt Environment/ Oxford Institute for Sustainable Development at Oxford BrookesUniversity for their warm reception in a world-class academic environment.

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