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 following the approval of projects, is often cited as a
major shortcoming of the environmental impact
assessment (EIA) process. The contents and recommendations 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 building a conceptual framework capable of serving the
needs of both. A key feature entails relating the
project actions or activities to environmental impacts via interaction processes, defined as ‘environmental 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: lsanchez@usp.br. 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: thacking@angloamerican.co.uk.
Impact Assessment and Project Appraisal March 2002
T
ODAY ENVIRONMENTAL PLANNERS
and managers have access to a plethora of
tools conceived to respond to particular problems 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 issues that these tools aim to address.
Many of the environmental management tools
now in use evolved from environmental impact assessment (EIA) ideas and concepts but, in order to
respond to specific needs, developed their own approaches, 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 different countries, authorities and organisations use
different terms. Once a project has been approved,
an EMS can help to ensure that the capacity exists to
1461-5517/02/0010025-14 US$08.00 IAIA 2002
25
Linking EIA and environmental management systems
implement the necessary environmental management and to optimise day-to-day operations, thus
further reducing harmful consequences and maximising 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 accidental, since both aim to answer the same questions —
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
Develop management
plans (mitigation,
enhancement and
compensation
measures)
4.3.3 Environmental objectives and
targets
4.3.4 Environmental management
programme(s)
Implementation and
management phase
The adjacent EMS items
may be conceptually
covered in the EIA
management plans
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
4.4.7 Emergence preparedness and
respons e
4.5 Checking and corrective
action
The adjacent EMS items
may be conceptually
covered in the EIA
management plans
4.5.1 Monitoring and measurement
4.5.2 Non-conformance and
corrective and preventive
action
4.5.3 Records
4.5.4 EMS audit
4.6 Management review
26
“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 potential impacts must be considered.
• Both processes require the ranking of these impacts according to their relative importance, but,
in EIA, ranking criteria will be submitted for public scrutiny. Although public input is also recommended 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 project?” The EIS is the vehicle for seeking approva l
for the project; hence the environmental consequences of the project need to be considered in detail. When an EMS is implemented at an operational
facility, the environmental consequences of the activities are usually only considered in sufficient detail 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 ‘audience’ is primarily internal. The company’s own
management can usually be persuaded by less rigorous 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 implementation of management plans a difficult task. On the
other hand, EMS standards tend to promote the design of more detailed action plans capable of meeting clearly defined objectives and goals. Plans
developed via the EMS approach are, therefore, usually more auditable than those developed using traditional 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) required to implement environmental management, to
confirm its effectiveness, and to ensure that improvements are made where this is possible or necessary. These items are usually only considered
conceptually in an EIA process and some (for instance, 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.
Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
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 conditions in their permits or licences. Such terms and
conditions are often derived from the pr oponents’
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 requirements’ 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 decides 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 projects, 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 operational. Reasons for this include:
• Insufficient interaction between the EIS consultant 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
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
Impact Assessment and Project Appraisal March 2002
participated in the public consultation aimed at
identifying the consequences of the undertaking,
hence they would not be aware of the public perceptions 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 government 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 measures 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 recommendations 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 bureaucratic requirement rather than justified on the
basis of thorough investigation.
Enhancing EIA usefulness to environmental management requires two sets of changes:
• A change in attitude towards the EIA process.
Proponents need to recognise the potential contribution 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 applied by a competent team they could together
deliver enhanced and cost-effective solutions for
better environmental outcomes.
This paper addresses the second challenge. It assumes 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
27
Linking EIA and environmental management systems
Table 2. General types of cause–effect models
Model type
Activity
Causal mechanism
Causal mechanism separated out
Hazardous waste disposal
Casual mechanism built into the activity
description
Hazardous waste disposal site releases contaminated
seepage
Casual mechanism built into impact
description
Hazardous waste disposal
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 management tool is adequate identification of the key
issues. Many EISs do not correctly describe the expected impacts and some even mistake an action (the
cause) for the impact (the consequence). When pla nning an EMS, correct impact identification is essential, since the establishment of objectives and targets
and consequent management programmes will depend 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 (different 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 activities 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
Contaminated seepage
Environmental impact
Groundwater pollution
Groundwater pollution
Contaminated seepage causes groundwater pollution.
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 standard, 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 defines environmental aspect as “an element of an organisation’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 environmental consequences, or impacts.
The manner in which the term ‘environmental effect’ is defined and used in BS7750 indicates that
they have basically chosen to merge the causal
mechanism with the impact side of the chain. However, the explanations and examples given (emissions 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 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
Environmental impact
British Standards
Institution
(BSI, 1992)
Munn (1975)
Element of an organisation’s activities,
products or services that can interact with
the environment
Environmental effect
Any direct or indirect impingement of the activities, products or services of
the organisation on the environment
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
28
Any change to the environment, whether adverse or beneficial,
wholly or partially resulting from an organisation’s activities,
products or services
(The standard does not focus on
the detailed assessment of
impacts)
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
Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
changes result from human-induced actions, which
modify one or more processes (environmental effects). 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 ni 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 intensifies erosion.
Munn’s work was clearly an attempt to understand 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 interactions is the concept of ‘processes’ used by natural 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 attempt to improve and facilitate EIS preparation and
review, systematically described 20 geological processes 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 discharge 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 processes, while engineers are more familiar with
industrial processes. Aspects are outcomes of industrial 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
Project actions
(activities/
products/
services)
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 environmental change (a consequence) via the causal
mechanism should be the thrust of correct impact
identification and, hence, of successful environmental management. Management can only be focused 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 focusing on these common features it is possible to
find synergies. This primarily involves ensuring that
the EIA methodology sets the stage for the subsequent EMS planning stage. This can be achieved
utilising an ‘EMS friendly’ approach during the EIA
process. The pivotal concept is the use of the activity–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 generalised 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
Environmental
aspects
Environmental
impacts
Figure 1. Cause–effect relationship linking a project action to an environmental impact
Impact Assessment and Project Appraisal March 2002
29
Linking EIA and environmental management systems
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’, environmental impacts could only result from the fact that
the ‘black box’ will occupy space. Additional impacts would only result if there were inputs to or
outputs from the ‘black box’. Therefore, the identif ication of aspects associated with project activities
involves:
Table 4. Main activities in an hypothetical gold mine
• 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 aspects 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 dependent 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 detail of subdivision is usually the same as would be
used for overall project planning or for line management 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
Social
Outputs
Inputs
Incidents
Land
transformation
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
facilitate the process of screening out the aspects
that require further consideration.
If public consultation is undertaken, it is convenient 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 concerns 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 project implementation is a standard component of EIS
preparation. It is the background against which project 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 ‘environments’. The most appropriate subdivision
varies and depends on the environmental setting and
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
Figure 2. A representation of a project's interaction with its
environment.
30
Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
Table 5. Simplified process flow diagram for an hypothetical gold mine
Green Mountain Gold Mine
Simplified process flow diagram — operational phase
Inputs
External
Activities
On-site
Electricity (from grid)
Water (from river)
Outputs
On-site
External
Used tyres
Equipment for repair
In-pit water
Diesel/oil spills?
Dust
Noise
Diesel
Explosives
In-pit/process water
(dust suppression)_
Open pit mining
In-pit/process water
(dust suppression)
Overburden
disposal
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
Electricity
Chemicals
Equipment and spares
Used tires
Damaged equipment
Reject chemicals
Diesel
Explosives
Chemicals
Equipment and spares
Dust
Noise
Runoff
Support services
Electricity
Process water
Chemical spills?
Scrap metal
Reject chemicals
Used oils
General waste
Sewage
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
Impact Assessment and Project Appraisal March 2002
Dust
Noise
Runoff from dumps
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 itised 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 affected are only described superficially.
When developing an EMS, significant aspects are
31
Linking EIA and environmental management systems
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
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
Human
identified on the basis of the significance of their
impacts on the environment. By assessing the impacts during the EIS stage and creating the linkage
with the responsible environmental aspects it will be
possible to have the justification required to determine 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 apply 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 associated with each aspect. Table 8 contains a list of
the typical categories of environmental aspects and
impacts usually encountered in many industrial projects. The ‘Nature of interaction’ column refers to
Figure 2.
If an environmental aspect is present, it does not
necessarily mean that significant environmental impacts 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
32
determine whether a particular aspect is significant.
This process is not well defined in the EMS standards. Therefore, a fair degree of iteration is unavoidable during the assessment process.
Criteria used to determine the significance of environmental impacts should be defined and used
consistently during EIS preparation. If these are
clearly defined and documented at the EIS preparation 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 management 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 operational 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 alternatives on the significance of the aspects must be
considered.
Although many organisations prepare EMSs during the operational phase of an undertaking, EMSs
could also be used to manage a project during its
Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
Table 8. Typical categories of environmental aspects and impacts associated with projects
Nature of
interaction
Interaction
inside project
boundaries
Main categories
Natural habitat loss
Loss of agricultural land
Reduced agricultural output
Reduced soil quality
Visual impact
Degradation of built environment
Loss of cultural resources
On site
Fires, explosions, equipment,
accidents, chemical spills etc
Possible injury and death
Soil contamination
Off site
Accidents during transportation to Possible injury and death
site
Soil contamination
Resource
consumption
Raw materials consumption
Manufactured products use
Energy use
Depletion of resource base
Indirect impacts due to energy production
and transport
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
Other releases
Noise emissions
Vibrations emissions
Radiation emissions
Public annoyance
Human health impact
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 diseases
Community disturbance
Increased workforce capacity
Increased tax collection
Decreased disposable income
Land transformation
Inputs
Outputs
Social
Impacts (examples)
Land clearing
Soil disturbance
Topographical change
Infrastructure disturbance
Land use restriction
Land access restriction
Incidents
Interaction
outside project
boundaries
Aspects (examples)
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 project alternatives should also be considered.
The aspects and impacts associated with the various project activities can be summarised using a
matrix format. The aspects and impacts due to the
operational phase of the hypothetical Green Mountain 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 aspects 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 environmental 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
Impact Assessment and Project Appraisal March 2002
the level of detail will be determined by how the
team decides to divide up the project into its component actions. Variations of this matrix may be conceived. For example, Figure 4 shows the impacts as
descriptive statements instead of classifying them
according to environmental ‘compartments’. Additional 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 indicators should be selected. Predictions about the future
behaviour of the indicators can then inform decisionmakers 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 determine (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 feature in the normal monitoring record.
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Linking EIA and environmental management systems
Figure 3. Operational phase of Green Mountain Gold Mine classifying impacts by environmental compartments
34
Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
Figure 4. Operational phase of Green Mountain Gold Mine classifying impacts as descriptive statements
Impact Assessment and Project Appraisal March 2002
35
Linking EIA and environmental management systems
Table 9. Recommended structure for reviews of legal and other requirements
Requirement
Activities
Aspects
Environment
Influence the location, appearance,
Governs the quantity and/or quality of
characteristics etc of the infrastructure inputs and outputs; nature and extent
and equipment
of land use and the and/or
characteristics of social aspects
Restricts damage to the environment
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
Air quality: particulate matter
concentration may not exceed daily
peaks of 240ug/m3; annual average
may not exceed 80ug/m3
Typical
requirements
Hypothetical
examples
Surface water: Effluent may not be
discharged into a Category I river
The lack of a baseline against which to compare
actual (and predicted) impacts is extremely common
because of inadequate EIA prior to the implementation of the project. If an EIA is properly undertaken,
the baseline should be well established when commencing 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 signific ant 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 implementation 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 requirements may regulate or restrict activities (for
instance, pr ohibition of underground storage tanks),
others may set performance standards for environmental aspects and yet others may limit the nature or
magnitude of environmental impacts.
‘Capacity’ management
‘Curative’ management
‘Preventative’ management
Activities
Aspects
Impacts
Figure 5. Different approaches to environmental management
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Impact Assessment and Project Appraisal March 2002
Linking EIA and environmental management systems
Table 10. Examples of management actions
Management type
‘Preventative’
or
‘proactive’
management
Purpose
To control the organis ation’s
activities, products or
services so as to influence
the potential of the aspects
to cause impacts
Examples: Green Mountain Gold Mine
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
‘Capacity’
management
To set in place the
resources, skills etc required
for effective ‘preventative’
and ‘curative’ management.
Allocate accountabilities and responsibilities
Pay compensation to landowners for crop damage caused by chemical spills
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)
Management plans
The first priority for management should be to reduce 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 result in impacts in the first place (that is, ‘preventing’). 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’ management requirements are covered by the ‘implementation and operation’, ‘checking and corrective
action’ and ‘management review’ EMS ele ments.
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 activities or aspects in order to reduce negative environmental impacts and enhance positive impacts.
In many EISs management measures are
presented environment-by-environment, that is, they
are described according to the particular environmental 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 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
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’)
Impact Assessment and Project Appraisal March 2002
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 overflow water will be recirculated to the ore washing facility
37
Linking EIA and environmental management systems
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 management 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 example is reworded and shown in Table 12.
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 aspects and to link these aspects to the environments
on which they impact.
References
Conclusion
EIA and EMSs are two of the tools used to plan and
manage human activities so as to reduce their negative environmental and social impacts. Many practitioners are specialised in one tool and often
misunderstand or simply neglect the other. As a result, EMS does not build on existing EIA documents; conversely, EIA is not designed to provide
useful input for the EMS.
As a contribution to overcoming some of the
38
BSI, British Standards Institution (1992), BS 7750: Specification
for Environmental Management Systems (BSI, London).
Fornasari, N et al (1991), Physical Environment Changes Resulting from Engineering Works (Boletim 61, Instituto de Pesquisas Tecnológicas, São Paulo, in Portuguese).
ISO, International Organization for Standardization (1996),
14001:1996: Environmental Management Systems – Specification 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 Management, 1(4), pages 393–405.
Impact Assessment and Project Appraisal March 2002