how to integrate eia in ems

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Impact Assessment and Project Appraisal March 2002 1461-5517/02/0010025-14 US$08.00 IAIA 2002 25 Impact Assessment and Project Appraisal , volume 20, number 1, March 2002, pages 25–38, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK Integrative management An approach to linking environmental impact assessment and environmental management systems Luis Enrique Sánchez and Theo Hacking The failure adequately to implement mitigation measures or monitor environmental impacts fol- lowing the approval of projects, is often cited as a major shortcoming of the environmental impact assessment (EIA) process. The contents and rec- ommendations of environmental impact statements (EISs) are often disregarded when environmental management systems (EMSs) are implemented. This paper focuses on a possible means of linking the EIA process to EMS implementation, by build- ing a conceptual framework capable of serving the needs of both. A key feature entails relating the project actions or activities to environmental im- pacts via interaction processes, defined as ‘envi- ronmental aspects’ by ISO 14001 sta ndard. The feasibility of constructing double-field matrices that are able to summarise all the relevant linkages is demonstrated. Application to a hypothetical mine illustrates the approach. Keywords: integrative environmental management; environmental impact assessment; environmental management systems Luis Enrique Sánchez is at the University of São Paulo, Escola Politécnica – PMI, Av. Prof. Mello Moraes, 2373, 05508-900 São Paulo, Brazil; E-mail: [email protected]. Theo Hacking at the time of writing was Environmental Manager at Konkola Copper Mines plc, Zambia; he is now Manager – Sustainable Development, Anglo American plc, 20 Carlton House Terrace, London SW1Y 5AN; E-mail: [email protected]. ODAY ENVIRONMENTAL PLANNERS and managers have access to a plethora of tools conceived to respond to particular prob- lems and situations. Minimising impacts over the life cycle of a product, improving the eco-efficiency of an industrial process and involving stakeholders in the decision-making process are a few of the is- sues that these tools aim to address. Many of the environmental management tools now in use evolved from environmental impact as- sessment (EIA) ideas and concepts but, in order to respond to specific needs, developed their own ap- proaches, methods and terminology. Following the world-wide dissemination of the ISO 14000 series of standards, environmental management systems (EMSs) emerged as a cost-effective tool to, among other things, help improve eco-efficiency and boost a company’s public image. Comparison between EIA and EMS Ideally, EIA is applied during the planning stage of a new project to help with, in particular, choosing the least disruptive location alternative and the best technological option, and to devise management measures to minimise negative impacts and enhance benefits. The document in which the findings of an EIA process are presented is often referred to as an environmental impact statement (EIS), although dif- ferent countries, authorities and organisations use different terms. Once a project has been approved, an EMS can help to ensure that the capacity exists to T

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Page 1: How to Integrate EIA in EMS

Impact Assessment and Project Appraisal March 2002 1461-5517/02/0010025-14 US$08.00 IAIA 2002 25

Impact Assessment and Project Appraisal , volume 20, number 1, March 2002, pages 25–38, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK

Integrative management

An approach to linking environmental impact assessment and environmental management systems

Luis Enrique Sánchez and Theo Hacking

The failure adequately to implement mitigation measures or monitor environmental impacts fol-lowing the approval of projects, is often cited as a major shortcoming of the environmental impact assessment (EIA) process. The contents and rec-ommendations of environmental impact statements (EISs) are often disregarded when environmental management systems (EMSs) are implemented. This paper focuses on a possible means of linking the EIA process to EMS implementation, by build-ing a conceptual framework capable of serving the needs of both. A key feature entails relating the project actions or activities to environmental im-pacts via interaction processes, defined as ‘envi-ronmental aspects’ by ISO 14001 standard. The feasibility of constructing double-field matrices that are able to summarise all the relevant linkages is demonstrated. Application to a hypothetical mine illustrates the approach.

Keywords: integrative environmental management; environmental impact assessment; environmental management systems

Luis Enrique Sánchez is at the University of São Paulo, Escola Politécnica – PMI, Av. Prof. Mello Moraes, 2373, 05508-900 São Paulo, Brazil; E-mail: [email protected]. Theo Hacking at the time of writing was Environmental Manager at Konkola Copper Mines plc, Zambia; he is now Manager – Sustainable Development, Anglo American plc, 20 Carlton House Terrace, London SW1Y 5AN; E-mail: [email protected].

ODAY ENVIRONMENTAL PLANNERS and managers have access to a plethora of tools conceived to respond to particular prob-

lems and situations. Minimising impacts over the life cycle of a product, improving the eco-efficiency of an industrial process and involving stakeholders in the decision-making process are a few of the is-sues that these tools aim to address.

Many of the environmental management tools now in use evolved from environmental impact as-sessment (EIA) ideas and concepts but, in order to respond to specific needs, developed their own ap-proaches, methods and terminology. Following the world-wide dissemination of the ISO 14000 series of standards, environmental management systems (EMSs) emerged as a cost-effective tool to, among other things, help improve eco-efficiency and boost a company’s public image.

Comparison between EIA and EMS

Ideally, EIA is applied during the planning stage of a new project to help with, in particular, choosing the least disruptive location alternative and the best technological option, and to devise management measures to minimise negative impacts and enhance benefits. The document in which the findings of an EIA process are presented is often referred to as an environmental impact statement (EIS), although dif-ferent countries, authorities and organisations use different terms. Once a project has been approved, an EMS can help to ensure that the capacity exists to

T

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Linking EIA and environmental management systems

26 Impact Assessment and Project Appraisal March 2002

implement the necessary environmental manage-ment and to optimise day-to-day operations, thus further reducing harmful consequences and maxi-mising benefits.

Despite the global dissemination of both EIA and EMS as widespread environmental planning and management tools, their interrelationships remain poorly understood by many practitioners, proponents and regulatory officials (Ridgway, 1999). Hence, these two key tools often exist as ‘islands’ without clearly defined bridges between them.

Table 1 compares the elements or components that comprise a typical EIA process and an EMS based on the ISO 14001 standard (ISO, 1996). For the purposes of comparison, the EIA process has been simplified by ignoring, for example, the iterative nature of a number of the components and their integration with the project planning life cycle.

The table indicates that there is considerable common ground between the planning stage of the EMS and a typical EIA process. This is not acciden-tal, since both aim to answer the same questions —

“What needs to be managed?” and “How should it be managed?”.

A number of significant common tasks and some fundamental differences are:

• Impact identification is the initial step common to both tools. However, an important difference is that in the EIS preparation potential impacts are identified, while in an EMS both actual and po-tential impacts must be considered.

• Both processes require the ranking of these im-pacts according to their relative importance, but, in EIA, ranking criteria will be submitted for pub-lic scrutiny. Although public input is also recom-mended in EMS, the decision whether or not to solicit and how to incorporate these views rests exclusively internally.

A question that is emphasised in an EIA process, but which does not feature strongly in an EMS is: “What will be the environmental consequences of the pro-ject?” The EIS is the vehicle for seeking approval for the project; hence the environmental conse-quences of the project need to be considered in de-tail. When an EMS is implemented at an operational facility, the environmental consequences of the ac-tivities are usually only considered in sufficient de-tail for management to be prioritised. The reason for this is that, unlike in an EIS where the consequences have to be justified to external parties, an EMS ‘au-dience’ is primarily internal. The company’s own management can usually be persuaded by less rigor-ous arguments than would be required to convince external parties.

Management measures and action plans are part of both processes, but these are much more detailed in EMS planning. Mitigation and other measures arising from EIA are sometimes stated in vague and imprecise terms; hence they need to be ‘translated’ and interpreted to become practical instructions for implementation. This makes auditing the implemen-tation of management plans a difficult task. On the other hand, EMS standards tend to promote the de-sign of more detailed action plans capable of meet-ing clearly defined objectives and goals. Plans developed via the EMS approach are, therefore, usu-ally more auditable than those developed using tradi-tional EIA methods.

Basically the implementation and operation, checking and corrective action, and management review EMS elements focus on the institutional capacity (administration, resources and so on) re-quired to implement environmental management, to confirm its effectiveness, and to ensure that im-provements are made where this is possible or nec-essary. These items are usually only considered conceptually in an EIA process and some (for in-stance, document control) are often not considered at all, since they are regarded as dealing with issues that are only relevant once the project has been implemented.

Table 1. Comparison between EIA and EMS

Typical EIA process ISO 14001 EMS

Project planning

Screening and scoping 4.2 Environmental policy

4.3 Planning

Describe project activities Obtain public comments Describe the baseline

environment Identify, predict and

assess impacts

4.3.1 Identify environmental aspects (and impacts)

Identify legal and other requirements

4.3.2 Legal and other requirements

4.3.3 Environmental objectives and targets

Develop management plans (mitigation, enhancement and compensation measures)

4.3.4 Environmental management programme(s)

Implementation and management phase

4.4 Implementation and operation

4.4.1 Structure and responsibility 4.4.2 Training, awareness and

competence 4.4.3 Communication 4.4.4 EMS documentation 4.4.5 Document control 4.4.6 Operational control

The adjacent EMS items may be conceptually covered in the EIA management plans

4.4.7 Emergence preparedness and respons e

4.5 Checking and corrective action

4.5.1 Monitoring and measurement 4.5.2 Non-conformance and

corrective and preventive action

4.5.3 Records

The adjacent EMS items may be conceptually covered in the EIA management plans

4.5.4 EMS audit

4.6 Management review

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Impact Assessment and Project Appraisal March 2002 27

Linkage between EIA and EMS

Project proponents, regulators and interested parties would benefit in many ways from greater EIA–EMS integration. This applies particularly to the process of converting the management measures proposed in an EIS into enforceable commitments, which is common practice in many jurisdictions where the government authority incorporates terms and condi-tions in their permits or licences. Such terms and conditions are often derived from the proponents’ commitments described in the EIS, modified or adapted to reflect public concerns so as to become enforceable or legally binding requisites. Hence they need to be considered under ‘legal and other re-quirements’ when implementing an EMS. The EMS’s ‘environmental management programmes’ will then translate them into verifiable actions.

Another potential benefit of EIA–EMS integration is that the effort to describe the affected environment and to identify impacts during the EIA process would not be duplicated once the organisation de-cides to implement an EMS.

Of course, EIA and EMS do not aim to achieve the same goal and this is why both are needed. Later in the paper it will be suggested that, for new pro-jects, the initial EIA process should be designed to be compatible with the EMS planning requirements. In this way the EIA could provide a clear starting point for the EMS.

Obstacles to linking EIA and EMS

In practice there is often poor linkage between the EIS produced to gain approval for a project and the EMS that is implemented once the project is opera-tional. Reasons for this include:

• Insufficient interaction between the EIS consult-ant and the proponent project team.

• Operational staff are often a completely new team that do not fully “buy into” the work undertaken by the project team. In addition, the operational management team often would not have

partic ipated in the public consultation aimed at identifying the consequences of the undertaking, hence they would not be aware of the public per-ceptions or of the reasons that led to the adoption of a particular management measure.

• Public debate during the approval process tends to concentrate on whether or not to grant permission for the project. Discussions are seldom directed towards the technical details of managing the project.

• The EIA process is often viewed by project proponents as a bureaucratic step to obtain a gov-ernment permit, rather than a useful planning process that will assist in the actual operation of the project.

Why EIA–EMS integration is beneficial

A generally recognised shortcoming of the EIA process is poor implementation of mitigation meas-ures and management plans. The reasons for this include:

• EISs often do not clearly provide a basis for the design of management plans.

• The recommendations presented in EISs are generally stated in terms that are too broad and generic. In order to be implemented these recom-mendations need to be ‘translated’ into a set of clear procedures and/or instructions.

• In certain jurisdictions, the management measures proposed in EISs are modified by the permitting authorities to accommodate the officials’ desire for ‘standardised’ management. In the process, the relevance of the management may be lost, since it is not clearly based on the outcomes of the EIA process. Operational staff are inclined to resist management that appears to be merely a bureau-cratic requirement rather than justified on the basis of thorough investigation.

Enhancing EIA usefulness to environmental man-agement requires two sets of changes:

• A change in attitude towards the EIA process. Proponents need to recognise the potential con- tribution that EIA can make to the ongoing management of the project.

• The available ‘toolkit’ must be integrated. EIA and EMS are powerful tools. If integrated and ap-plied by a competent team they could together deliver enhanced and cost-effective solutions for better environmental outcomes.

This paper addresses the second challenge. It as-sumes that, by slightly adapting EIS preparation methods or practices, it would be possible to deliver a value-added product, that is, an EIS that is more useful for management purposes, while maintaining its other roles in the EIA process, namely a tool for

One benefit of integrating environmental impact assessment and the environmental management system is that the effort to describe the affected environment and identify impacts in the EIA would not be duplicated once it is decided to implement an EMS

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28 Impact Assessment and Project Appraisal March 2002

project planning, providing a basis for negotiating with interested and affected parties, and informing the decision-making process.

Linkage between activities and impacts

The core of any environmental planning or man-agement tool is adequate identification of the key issues. Many EISs do not correctly describe the ex-pected impacts and some even mistake an action (the cause) for the impact (the consequence). When plan-ning an EMS, correct impact identification is essen-tial, since the establishment of objectives and targets and consequent management programmes will de-pend on this identification.

A number of techniques have been devised to help practitioners to identify environmental impacts. Most of the techniques rely on a cause–effect model, that is, project components, actions or activities (dif-ferent names are used with similar meanings) are the cause of changes in the state of the environment. The changes may be harmful or beneficial and are often termed ‘impacts’.

The most successful models aim to identify the causal mechanisms responsible for ‘linking’ the ac-tivities to environmental changes. Some models do not explicitly separate out the causal mechanisms, but rather incorporate them into the description of the activities or identification of the environmental impacts. This can be illustrated as shown in Table 2.

The ‘activity–causal mechanism–environmental

impact’ chain concept is not new and features in, for example, an early work by Munn (1975). It has also been adopted by the ISO 14001 standard, which largely evolved from an earlier British EMS stan-dard, BS7750 (BSI, 1992). However, even though common ground exists, this is not always clear, since different terminology and definitions are used in the models. The examples in Table 3 illustrate this point.

Of the examples given, only the ISO model explicitly separates out and defines the causal mechanism as an ‘environmental aspect’. The term ‘aspect’ is sometimes confusing because it is widely used in everyday language. The ISO standard de-fines environmental aspect as “an element of an org- anisation’s activities, products or services that can interact with the environment”. The key word here is “interact”, as it suggests that an aspect is the linkage between an activity, product or service and their en-vironmental consequences, or impacts.

The manner in which the term ‘environmental ef-fect’ is defined and used in BS7750 indicates that they have basically chosen to merge the causal mechanism with the impact side of the chain. How-ever, the explanations and examples given (emis-sions to atmosphere, discharges to water and so on) indicate that their emphasis is on the identification of the causal mechanisms rather than on the detailed assessment of the resulting environmental changes. (As previously mentioned, this is the appropriate emphasis for an EMS, but would not be for an EIA.)

Munn chose to emphasise that environmental

Table 2. General types of cause–effect models

Model type Activity Causal mechanism Environmental impact

Causal mechanism separated out Hazardous waste disposal Contaminated seepage Groundwater pollution

Casual mechanism built into the activity description

Hazardous waste disposal site releases contaminated seepage

Groundwater pollution

Casual mechanism built into impact description

Hazardous waste disposal Contaminated seepage causes groundwater pollution.

Table 3. Examples of difference in the terminology used in environmental cause–effect models

Source Causal mechanism Environmental change

International Organisation of Standardisation (ISO, 1996)

Environmental aspect

Element of an organisation’s activities, products or services that can interact with the environment

Environmental impact

Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or services

British Standards Institution

(BSI, 1992)

Environmental effect

Any direct or indirect impingement of the activities, products or services of the organisation on the environment

(The standard does not focus on the detailed assessment of impacts)

Munn (1975) Environmental effect

A process (such as erosion of soil, the dispersion of pollutants, the displacement of persons) that is set in motion or accelerated by human actions

Environmental impact

The net change (good or bad) in human health and well-being (including the well-being of the ecosystems on which human survival depends) that results from an environmental effect and is related to the difference between the quality of the environment as it would exist with and without the same action

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Impact Assessment and Project Appraisal March 2002 29

changes result from human-induced actions, which modify one or more processes (environmental ef-fects). Such modifications can affect environmental quality, thus causing an environmental impact. He illustrates that human-induced actions can modify (by intensification or reduction) or even initiate natural or social processes. Water erosion, for in-stance, is a natural process occurring all over the Earth’s surface. Therefore, stating that that the construction of a road causes erosion is not strictly correct, it is more correct to say that a road intensi-fies erosion.

Munn’s work was clearly an attempt to under-stand the mechanisms by which environmental changes are caused by human actions. Munn tended to focus on the environmental change side of the chain, which is not uncommon when the outcome is intended to be an EIS, as opposed to an EMS.

Yet another attempt to describe environmental in-teractions is the concept of ‘processes’ used by natu-ral scientists. Erosion is, once again, a convenient example to illustrate this concept. It is a natural process, which can be modified by human action. Mining, road building, forestry, and a number of other undertakings change natural erosion patterns: sheet erosion can be intensified, gullies can develop and even mass movements (such as landslides) can occur as consequences of human activity.

Many biophysical interactions can be described in terms of processes. Fornasari et al (1991), in an at-tempt to improve and facilitate EIS preparation and review, systematically described 20 geological pro- cesses that can be affected by engineering projects. Ecologists also describe several interactions as processes, such as succession, eutrophication and pollutant bioaccumulation.

An environmental effect (in Munn’s terms) is a modification in a natural process. An environmental aspect (in ISO 14001 terms), for instance, the dis-charge of contaminated effluent, is the ‘mechanism’ that can modify a natural process; for instance, water pollution can reduce the productivity of a river system.

Natural scientists are familiar with natural pro- cesses, while engineers are more familiar with industrial processes. Aspects are outcomes of indus-trial processes. Since people coming from the business/industrial sector have largely developed the ISO 14000 series of standards, they employ their terminology and concepts rather than those used by

natural scientists, who are often involved in EIS preparation and review.

Regardless of the terminology used, the concept of linking an activity or action (cause) to an envi-ronmental change (a consequence) via the causal mechanism should be the thrust of correct impact identification and, hence, of successful environ-mental management. Management can only be fo-cused if what needs to be managed is understood.

Since the purpose of this paper is to find ways of linking EIA and EMS, the terminology adopted by the ISO series of EMS standards will be favoured in the remainder of the text. This can be illustrated as shown in Figure 1.

An approach to linking EIA and EMS

In order to prepare an EIS and to implement an EMS a number of common tasks must be fulfilled. By fo-cusing on these common features it is possible to find synergies. This primarily involves ensuring that the EIA methodology sets the stage for the subse-quent EMS planning stage. This can be achieved utilising an ‘EMS friendly’ approach during the EIA process. The pivotal concept is the use of the activ-ity–aspect–environmental impact linkage promoted in the ISO14001 standard.

The approach is described below and is illustrated by means of a hypothetical gold mine. The general-ised EIA sections listed below are considered. For each one, it is shown how a link can be made to the EMS process, thereby adding value to the EIA.

• Description of the project activities • Public consultation • Description of the baseline environment • Impact identification, prediction and assessment • Legal and other requirements • Management plans

Description of the project activities

To be able to predict the environmental changes that a proposal can cause it is necessary to understand the mechanisms by which the project activities can interact with the environment. In ISO 14001 EMS terminology this is referred to as “identifying the environmental aspects”. As illustrated by the examples given in Table 2, this step is not always

Project actions (activities/ products/ services)

Environmental aspects

Environmental impacts

Figure 1. Cause–effect relationship linking a project action to an environmental impact

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30 Impact Assessment and Project Appraisal March 2002

explicit in EIA processes. However, the transition from an EIA to an EMS is greatly facilitated if the causal mechanisms (environmental aspects) are clearly identified during the EIA process.

Aspects can be conceptualised by regarding an organisation as a ‘black box’. If a project involved a completely self-contained ‘black box’, environ-mental impacts could only result from the fact that the ‘black box’ will occupy space. Additional im-pacts would only result if there were inputs to or outputs from the ‘black box’. Therefore, the identif i-cation of aspects associated with project activities involves:

• Establishing the manner in which it will occupy the site.

• Identifying the inputs and outputs.

This can be illustrated as shown in Figure 2. An understanding of the activities that take place

within the ‘black box’ is required to identify the as-pects that are (or could be) associated with them. This can best be illustrated by an example, such as that given in Table 4.

The inputs and outputs are best identified by a process flow diagram (Table 5). Possible inputs or outputs due to adverse operating conditions or as a result of incidents should also be considered.

The success of aspect identification is greatly de-pendent on appropriately subdividing the project into its component activities. At one extreme the entire mine could be considered as an activity and, at the other, every process unit could be treated as a separate activity. The most appropriate level of de-tail of subdivision is usually the same as would be used for overall project planning or for line man-agement responsibility during the operational phase.

Public comments

Identifying the aspects of concern should form part of the EIA scoping phase. During the scoping phase certain aspects can be eliminated ‘by inspection’ or from preliminary technical investigations. It is also generally accepted good practice to undertake public consultation as part of the scoping phase although in many countries this is not a legal requirement. The views/concerns/suggestions obtained by consulting with the interested and affected parties can greatly

facilitate the process of screening out the aspects that require further consideration.

If public consultation is undertaken, it is conven-ient to ‘unpack’ the comments that are recorded in accordance with the ‘activity–aspect–environmental impact’ model. By doing so, the comments can be clearly linked to the analysis presented in the EIS. Table 6 furnishes an example of how public con-cerns can be understood in terms of this model.

This can be used during the preparation of the EMS to help develop operational procedures, the environmental management programme and the community liaison/consultation programme.

Description of the baseline environment

A description of conditions prevailing prior to pro-ject implementation is a standard component of EIS preparation. It is the background against which pro-ject actions will be analysed and impacts will be identified, predicted and assessed. When considering impacts, the environment is usually (for clarity and convenience) divided into a number of separate ‘en-vironments’. The most appropriate subdivision varies and depends on the environmental setting and

Inputs

Outputs

Land transformation

Social

Incidents

Figure 2. A representation of a project's interaction with its environment.

Table 4. Main activities in an hypothetical gold mine

Green Mountain Gold Mine

The operational phase of the Green Mountain Gold Mine involves the following main activities:

• Open pit mining

• Disposal of overburden at dumps

• Metallurgical processing to extract the gold

• Tailings disposal

• Support services (workshops, water and energy supply, waste recovery etc)

• Materials transport to site

• Land rehabilitation

Note: For a full and detailed assessment, these activ ities should be further divided into other component activities. Thus open pit mining would include, for example, vegetation removal, topsoil removal and storage, overburden removal, rock drilling, rock blasting, ore hauling, groundwater pumping

Appropriate subdivision of the project into component activities is important: the most appropriate level of detail is usually the same as for overall project planning or for line management responsibility during the operational phase

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Impact Assessment and Project Appraisal March 2002 31

the nature of the organisation’s activities, and on the standard practice and legal requirements of each jurisdiction. ‘Environments’ that lend themselves to fairly general application are defined in Table 7, which also contains examples of the criteria that could be used to ‘measure’ environmental value.

The level of detail provided in the description of the various environments in the EIS must be prior i-tised in relation to their sensitivity to the project. Often voluminous descriptions are provided for environments that will be virtually unaffected by a project because the information happens to be easily available, while those that may be significantly af-fected are only described superficially.

When developing an EMS, significant aspects are

Table 5. Simplified process flow diagram for an hypothetical gold mine

Green Mountain Gold Mine Simplified process flow diagram — operational phase

Inputs Activities Outputs

External On-site On-site External

Diesel Explosives

In-pit/process water (dust suppression)_

Open pit mining

Used tyres Equipment for repair

In-pit water Diesel/oil spills?

Dust Noise

In-pit/process water (dust suppression)

Overburden disposal

Dust Noise

Runoff from dumps

Electricity Chemicals

In-pit/recovered/ return/process water

Metallurgical processing

Tailings Recovered water Reject chemicals Chemical spills?

Runoff from plant site Dust, gases and fumes

Tailings

Process water (irrigation)

Tailings disposal

Return water Tailings spills?

Dust Surplus water

Runoff from dam sides Seepage from dam

Tailings spills?

Fertilizers, Pesticides Seeds, seedlings

Topsoil

Land

rehabilitation

Dust Noise Runoff

Electricity (from grid) Water (from river)

Electricity Chemicals

Equipment and spares Used tires

Damaged equipment Reject chemicals

Support services

Electricity Process water

Chemical spills?

Scrap metal Reject chemicals

Used oils General waste

Sewage

Diesel Explosives Chemicals

Equipment and spares

Transport to site

Diesel

Chemicals Equipment and spares

Chemical spills?

Table 6. Example of ‘unpacking’ public comments

Comments Activity Aspect Environment of concern

Mr Brown (Farmer): “Seepage from the pit will contaminate my borehole”

Open pit

Contaminated seepage

Groundwater

Ms Jones (Conservationist): “The tailings disposal site will occupy a wetland area”

Tailings dam

Land occupation

Habitats and biodiversity

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32 Impact Assessment and Project Appraisal March 2002

identified on the basis of the significance of their impacts on the environment. By assessing the im-pacts during the EIS stage and creating the linkage with the responsible environmental aspects it will be possible to have the justification required to deter-mine the significance of the impacts identified during EMS implementation.

Impact identification and scoping

An appropriate technique to identify environmental impacts in order to integrate EIA and EMS is to ap-ply the activity–aspect–environmental impact model. Once project activities have been described, every relevant aspect needs to be associated with each activity and environmental impacts need to be asso-ciated with each aspect. Table 8 contains a list of the typical categories of environmental aspects and impacts usually encountered in many industrial pro-jects. The ‘Nature of interaction’ column refers to Figure 2.

If an environmental aspect is present, it does not necessarily mean that significant environmental im-pacts will result. For example, a project may require effluent to be discharged. However, if the effluent is of the same quality as the river water and is of such a small volume that it will not measurably alter the flow of the river, then no significant impacts will result from this aspect. In some cases it will be necessary to undertake the impact assessment to

determine whether a particular aspect is significant. This process is not well defined in the EMS stan-dards. Therefore, a fair degree of iteration is un-avoidable during the assessment process.

Criteria used to determine the significance of en-vironmental impacts should be defined and used consistently during EIS preparation. If these are clearly defined and documented at the EIS prepara-tion stage, the same criteria could later be employed in planning an EMS for the project, thus assuring that public concerns expressed during the project approval phase will also be considered for manage-ment purposes.

The aspect identification and ranking process is largely a scoping exercise. Aspects that do not have the potential to cause significant impacts are ranked ‘low’ and do not warrant further attention. Aspects causing impacts ranked in categories such as ‘high’ and ‘moderate’ are significant and will require op-erational control. The significance of the aspects should be ranked on the assumption that the management measures that are recommended in the EIA will be in place. This represents the scenario that the proponent wishes to have considered for approval. The influence of various project alterna-tives on the significance of the aspects must be considered.

Although many organisations prepare EMSs dur-ing the operational phase of an undertaking, EMSs could also be used to manage a project during its

Table 7. Typical sub-division of the environment

Environments Definition Examples of valuation criteria

Bio-physical

Soil and land capability The inherent value (agriculture, conservation etc) of the land Agricultural potential

Ecology/fauna and flora/ plants and animals/sensitive landscapes

Plants and animals and their inter-relationship Biodiversity Rarity or endangered status Uniqueness Conservation value

Surface water Rivers, streams, dams, pans etc Usefulness (recreation, industry, drinking, agriculture or environment)

Value as natural habitat

Groundwater Underground water Usefulness (recreation, industry, drinking, agriculture or environment)

Ocean Salt water bodies (oceans, seas and estuaries) Usefulness (recreation and environment) Value as natural habitat

Atmosphere/air Ambient air quality/noise levels/radiation levels Hazard or nuisance levels (to humans or the bio-physical environment)

Contribution to climate change

Earth’s resources The earth’s finites stock of non-renewable resources Available reserves

Human

Neighbours/communities Individuals or groupings of people Lifestyle Standard of living Health and welfare

Cultural/historical sites Archaeological sites, palaeontological sites, graves, national monuments etc

Age and rarity Cultural significance

Aesthetics/visual Appearance of the landscape Sense of place Compatibility with surroundings

Regional economy Production systems, consumption patterns and public sector Gross domestic product

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Impact Assessment and Project Appraisal March 2002 33

construction phase and during decommissioning. Most EIA regulations require proponents to identify impacts and mitigation measures for each major phase of a project. Thus to fully integrate both tools, the aspects and impacts of each phase should be identified and analysed. The impact of various pro-ject alternatives should also be considered.

The aspects and impacts associated with the vari-ous project activities can be summarised using a matrix format. The aspects and impacts due to the operational phase of the hypothetical Green Moun-tain Gold Mine are shown in Figure 3 in the form of a double-field matrix. The matrix should be read as follows:

• The left-hand side shows the environmental as-pects that are associated with each of the project actions (activities, products or services). Each action may cause one or more aspects.

• The right-hand side shows the environmental impacts anticipated to arise from each environ-mental aspect.

The double-field matrix thus provides a means of linking a particular project action to its impacts (via the interactions mechanisms or aspects). Notice that

the level of detail will be determined by how the team decides to divide up the project into its compo-nent actions. Variations of this matrix may be con-ceived. For example, Figure 4 shows the impacts as descriptive statements instead of classifying them according to environmental ‘compartments’. Addi-tional matrices can be prepared for the construction, decommissioning and post-closure scenarios.

Impact prediction and assessment

Impact prediction is key to EIA. After potential impacts have been identified, appropriate indica- tors should be selected. Predictions about the future behaviour of the indicators can then inform decision-makers as well as interested and affected parties about the future state of the environment, if the proposal were approved.

Impact prediction is usually not the main focus of an EMS because, in most cases, it is possible to de-termine (through an appropriate monitoring system) the actual impacts of the activities, products or services. Impacts that could result from accidents of abnormal operating conditions will, of course, always need to be predicted, since they will not fea-ture in the normal monitoring record.

Table 8. Typical categories of environmental aspects and impacts associated with projects

Nature of interaction

Main categories Aspects (examples) Impacts (examples)

Land transformation

Land clearing Soil disturbance Topographical change Infrastructure disturbance Land use restriction Land access restriction

Natural habitat loss Loss of agricultural land Reduced agricultural output Reduced soil quality Visual impact Degradation of built environment Loss of cultural resources

Interaction inside project boundaries

On site Fires, explosions, equipment, accidents, chemical spills etc

Possible injury and death Soil contamination

Incidents Off site Accidents during transportation to

site Possible injury and death Soil contamination

Resource consumption

Raw materials consumption Manufactured products use Energy use

Depletion of resource base Indirect impacts due to energy production

and transport Inputs

Water Groundwater abstraction/use River water abstraction/use

Reduced groundwater level Reduced water availability

Releases to water

Point sources (piped effluent) Diffuse sources (seepage/run-off)

Water quality deterioration Disturbance of aquatic ecosystems

Releases to air Dust emissions Gases and fumes emissions

Air quality deterioration Human health impact

Releases to soil Chemical seepage Solid waste disposal

Groundwater quality decrease Soil contamination

Outputs

Other releases Noise emissions Vibrations emissions Radiation emissions

Public annoyance Human health impact

Interaction outside project boundaries

Social

Demand for goods and services Provision of employment Creation of business opportunities Influx of outsiders Training Revenue generation (tax etc) Local prices rise

Increased commercial activity Population growth Increased demand for public services Possible dissemination of infectious diseasesCommunity disturbance Increased workforce capacity Increased tax collection Decreased disposable income

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Impact Assessment and Project Appraisal March 2002 34

Figure 3. Operational phase of Green Mountain Gold Mine classifying impacts by environmental compartments

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Figure 4. Operational phase of Green Mountain Gold Mine classifying impacts as descriptive statements

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The lack of a baseline against which to compare actual (and predicted) impacts is extremely common because of inadequate EIA prior to the implementa-tion of the project. If an EIA is properly undertaken, the baseline should be well established when com-mencing with the implementation of the EMS. This is another example of the advantage to be gained from integrating EIA and EMS.

Impact assessment is a requirement for both EIA and EMS. Where significant environmental aspects are present (‘high’ or ‘moderate’), significant environmental impacts may result. The significance of the impacts associated with the significant aspects can be determined by considering the risk:

Significance of environmental impact (risk) = probability × consequence

ISO 14004 standard (the companion to ISO 14001, providing guidelines for EMS implementation) draws on EIA experience to recommend criteria for ranking impacts according to their significance. It suggests that impacts can be analysed by considering

the severity, spatial extent, duration of the impact and its probability of occurrence. Legal and other requirements

Legal reviews undertaken as part of EIA processes may fulfil different functions, such as providing one set of criteria for judging the significance of impacts and providing an input for the scoping phase. When reviews are undertaken as part of EMS implementa-tion one of the main purposes is to identify the minimum performance requirements.

It is sometimes difficult to link legal requirements directly to management actions, but this difficulty can be addressed by clearly structuring the review results in accordance with the activity–aspect–environmental impact model. The examples given in Table 9 illustrate this approach. Some legal require-ments may regulate or restrict activities (for instance, prohibition of underground storage tanks), others may set performance standards for environ-mental aspects and yet others may limit the nature or magnitude of environmental impacts.

‘Preventative’ management ‘Curative’ management

‘Capacity’ management

Activities Aspects Impacts

Figure 5. Different approaches to environmental management

Table 9. Recommended structure for reviews of legal and other requirements

Requirement Activities Aspects Environment

Typical requirements

Influence the location, appearance, characteristics etc of the infrastructure and equipment

Governs the quantity and/or quality of inputs and outputs; nature and extent of land use and the and/or characteristics of social aspects

Restricts damage to the environment

Hypothetical examples

Administrative requirements

Open pit: Written approval must be obtained before mining commences

Releases to air: Dust fall out monitoring results must be submitted every three months

Ecology: Written approval is required from the Forestry Department before trees greater than 200mm in diameter are removed

Performance requirements

Tailings dam: Side slopes may not exceed 35°

Releases to water: Effluent quality must comply with the standards contained in Schedule X

Surface water: Effluent may not be discharged into a Category I river

Air quality: particulate matter concentration may not exceed daily peaks of 240ug/m3; annual average may not exceed 80ug/m3

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Management plans

The first priority for management should be to re-duce the significance of aspects, so that they will not have the potential to cause significant impacts. EISs often tend to focus on mitigating the impacts (that is, ‘curing’) rather than endeavouring to design and manage the project activities so that they do not re-sult in impacts in the first place (that is, ‘prevent-ing’). Overarching management aimed at ensuring that the necessary capacity exists to implement both preventative and curative management also often tends to be neglected in EISs.

As previously mentioned, these ‘capacity’ man- agement requirements are covered by the ‘imple-mentation and operation’, ‘checking and corrective action’ and ‘management review’ EMS elements. The difference in focus can be illustrated as shown in Figure 5.

The purpose and examples of the different types of environmental management are given in Table 10. Management actions must be associated with activi- ties or aspects in order to reduce negative environ- mental impacts and enhance positive impacts.

In many EISs management measures are

presented environment-by-environment, that is, they are described according to the particular environ-mental component they intend to protect. Table 11 shows a hypothetical example.

The authorities and other external parties are often satisfied with the layout illustrated in Table 11, since they are concerned with the environment rather than

Table 10. Examples of management actions

Management type Purpose Examples: Green Mountain Gold Mine

‘Preventative’ or ‘proactive’ management

To control the organis ation’s activities, products or services so as to influence the potential of the aspects to cause impacts

Re-circulate process water so as to reduce water consumption and effluent discharge and, hence, minimise impacts on surface water

Implement a community liaison programme so as to improve communication and, hence, improve relations with neighbouring communities

Develop, implement and rehearse emergency plans that equip employees to responds to incidents

‘Curative’ or ‘reactive’ management

To mitigate or remediate impacts, which are unavoidable, unforeseen or accidental

Rehabilitate the land disturbed by the organisation’s activities in order to restore the land capability of the area

Pay compensation to landowners for crop damage caused by chemical spills

‘Capacity’ management

To set in place the resources, skills etc required for effective ‘preventative’ and ‘curative’ management.

Allocate accountabilities and responsibilities

Provide adequate financial and other resources

Implement training and awareness-raising programmes

Maintain health, safety and environment records

Key: Bold = Management action Italics = Aspect Underlined = Environment (bio-physical social or workplace)

Environmental impact statements often tend to focus on mitigating the impacts (‘curing’) rather than endeavouring to design and manage the project activities so that they do not result in impacts in the first place (‘preventing’)

Table 11. Example of management measures from an EIS

Example: Green Mountain Gold Mine Extract from EIS Management Recommendations

6.2.3 Surface water management

Water collected in the in-pit sump will be used for haul road dust suppression

Construct paddocks around the tailings dam to trap silt eroding from the sides

In the metallurgical plant the tailings thickener overflow water will be re-circulated to the ore washing facility.

Table 12. Example of management measures from an ‘EMS friendly’ EIS

Example: Green Mountain Gold Mine Extract from Improved EIS Management Recommendations

6.2.3 Surface water management

a) Open pit

Water consumption: Water collected in the in-pit sump will be used for haul road dust suppression

b) Tailings dam

Water consumption/releases to water: Construct paddocks around the tailings dam to trap silt eroding from the sides

c) Metallurgical plant

Water consumption/releases to water: The tailings thickener over-flow water will be recirculated to the ore washing facility

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38 Impact Assessment and Project Appraisal March 2002

with the project activities. However, this layout is not ‘user friendly’ for the operational staff, since their day-to day responsibilities will be managing the activities. It is for this reason that the manage-ment contained in an EMS is usually presented activity-by-activity. Once again the transition to the EMS format can be facilitated by explicitly adopting the activity–aspect–environmental impact model at the EIA stage. Following the model, the same exam-ple is reworded and shown in Table 12.

Conclusion

EIA and EMSs are two of the tools used to plan and manage human activities so as to reduce their nega-tive environmental and social impacts. Many practi-tioners are specialised in one tool and often misunderstand or simply neglect the other. As a re-sult, EMS does not build on existing EIA docu-ments; conversely, EIA is not designed to provide useful input for the EMS.

As a contribution to overcoming some of the

practical difficulties in integrating the two tools, it is proposed in this paper that EIS preparation should be structured around the activity–aspect–impact model. Information regarding impact identification and classification can be organised and presented using double-field matrix diagrams to highlight the linkages between activities and their associated as-pects and to link these aspects to the environments on which they impact.

References

BSI, British Standards Institution (1992), BS 7750: Specification for Environmental Management Systems (BSI, London).

Fornasari, N et al (1991), Physical Environment Changes Result-ing from Engineering Works (Boletim 61, Instituto de Pes-quisas Tecnológicas, São Paulo, in Portuguese).

ISO, International Organization for Standardization (1996), 14001:1996: Environmental Management Systems – Specifi-cation with guidance for use (ISO, Geneva).

Munn, R E (1975), Environmental Impact As sessment. Princ iples and Procedures (John Wiley and Sons, Toronto).

Ridgway, B (1999), “The project cycle and the role of EIA and EMS”, Journal of Environmental Assessment Policy and Man-agement, 1(4), pages 393–405.