Impact Assessment and Project Appraisal , volume 20, number 1, March 2002, pages 2538, 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 Snchez 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 i m pacts 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

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 companys 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

Luis Enrique Snchez is at the University of So Paulo, Escola Politcnica PMI, Av. Prof. Mello Moraes, 2373, 05508-900 So 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

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

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 p otential 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 d etail. When an EMS is implemented at an operational facility, the environmental consequences of the a ctivities are usually only considered in sufficient d etail 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 companys 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) r equired 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 i n stance, document control) are often not considered at all, since they are r garded as dealing w issues e ith that are only relevant once the project has been implemented.
Impact Assessment and Project Appraisal March 2002

Typical EIA process Project planning Screening and scoping

ISO 14001 EMS

4.2 Environmental policy 4.3 Planning

Describe project activities Obtain public comments Describe the baseline environment Identify, predict and assess impacts Identify legal and other requirements Develop management plans (mitigation, enhancement and compensation measures) Implementation and management phase

4.3.1 Identify environmental aspects (and impacts)

4.3.2 Legal and other requirements 4.3.3 Environmental objectives and targets 4.3.4 Environmental management programme(s) 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

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

Linking EIA and environmental management systems

Linkage between EIA and EMS

Project proponents, regulators and interested parties would benefit in many ways from greater EIAEMS 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 EMSs environmental management programmes will then translate them into verifiable actions. Another potential benefit of EIAEMS 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 d ecides 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.

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 EIAEMS 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 b ased 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 a ssumes 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

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

27

Linking EIA and environmental management systems

Table 2. General types of causeeffect models

Model type Causal mechanism separated out Casual mechanism built into the activity description Casual mechanism built into impact description

Activity Hazardous waste disposal

Causal mechanism Contaminated seepage

Environmental impact Groundwater pollution Groundwater pollution

Hazardous waste disposal site releases contaminated seepage Hazardous waste disposal

Contaminated seepage causes groundwater pollution.

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 causeeffect 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 activitycausal mechanismenvironmental

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 d efines environmental aspect as an element of an organisations 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 causeeffect models

Source International Organisation of Standardisation (ISO, 1996) British Standards Institution (BSI, 1992) Munn (1975)

Causal mechanism Environmental aspect Element of an organisations activities, products or services that can interact with the environment

Environmental change Environmental impact Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisations activities, products or services (The standard does not focus on the detailed assessment of impacts)

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

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

28

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 Earths 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. Munns 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 Munns 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

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 f ocused 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 activityaspectenvironmental 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

Project actions (activities/ products/ services)

Environmental aspects

Environmental impacts

Figure 1. Causeeffect 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: 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 d ependent 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 d etail 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

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

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 activityaspectenvironmental 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

Outputs Inputs Land transformation Incidents

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 On-site Activities On-site Outputs 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 Groundwater

Mr Brown (Farmer): Seepage from the pit will contaminate my borehole Ms Jones (Conservationist): The tailings disposal site will occupy a wetland area

Open pit

Contaminated seepage

Tailings dam

Land occupation

Habitats and biodiversity

the nature of the organisations 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

Impact Assessment and Project Appraisal March 2002

31

Linking EIA and environmental management systems

Table 7. Typical sub-division of the environment

Environments Bio-physical Soil and land capability Ecology/fauna and flora/ plants and animals/sensitive landscapes Surface water

Definition

Examples of valuation criteria

The inherent value (agriculture, conservation etc) of the land Plants and animals and their inter-relationship

Agricultural potential Biodiversity Rarity or endangered status Uniqueness Conservation value Usefulness (recreation, industry, drinking, agriculture or environment) Value as natural habitat Usefulness (recreation, industry, drinking, agriculture or environment) Usefulness (recreation and environment) Value as natural habitat Hazard or nuisance levels (to humans or the bio-physical environment) Contribution to climate change Available reserves

Rivers, streams, dams, pans etc

Groundwater Ocean Atmosphere/air

Underground water Salt water bodies (oceans, seas and estuaries) Ambient air quality/noise levels/radiation levels

Earths resources Human Neighbours/communities

The earths finites stock of non-renewable resources

Individuals or groupings of people

Lifestyle Standard of living Health and welfare Age and rarity Cultural significance Sense of place Compatibility with surroundings Gross domestic product

Cultural/historical sites Aesthetics/visual Regional economy

Archaeological sites, palaeontological sites, graves, national monuments etc Appearance of the landscape Production systems, consumption patterns and public sector

identified on the basis of the significance of their impacts on the environment. By assessing the i m pacts 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 activityaspectenvironmental 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 i m 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
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 u navoidable 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 o perational 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 Main categories Aspects (examples) Land clearing Soil disturbance Topographical change Infrastructure disturbance Land use restriction Land access restriction Fires, explosions, equipment, accidents, chemical spills etc Impacts (examples) Natural habitat loss Loss of agricultural land Reduced agricultural output Reduced soil quality Visual impact Degradation of built environment Loss of cultural resources Possible injury and death Soil contamination

Interaction inside project boundaries

Land transformation

On site Incidents Off site Resource consumption Inputs Water Releases to water Interaction outside project boundaries Releases to air Outputs Releases to soil Other releases

Accidents during transportation to Possible injury and death site Soil contamination Raw materials consumption Manufactured products use Energy use Groundwater abstraction/use River water abstraction/use Point sources (piped effluent) Diffuse sources (seepage/run-off) Dust emissions Gases and fumes emissions Chemical seepage Solid waste disposal Noise emissions Vibrations emissions Radiation emissions Demand for goods and services Provision of employment Creation of business opportunities Influx of outsiders Training Revenue generation (tax etc) Local prices rise Depletion of resource base Indirect impacts due to energy production and transport Reduced groundwater level Reduced water availability Water quality deterioration Disturbance of aquatic ecosystems Air quality deterioration Human health impact Groundwater quality decrease Soil contamination Public annoyance Human health impact 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

Social

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 a spects 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.

33

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 Typical requirements

Activities

Aspects

Environment Restricts damage to the 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

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

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

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 a ctions, but this difficulty can be addressed by clearly structuring the review results in accordance with the activityaspect 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

Preventative management

Curative management

Activities

Aspects

Impacts

Figure 5. Different approaches to environmental management

36

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 ations 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 Capacity management

To mitigate or remediate impacts, which are unavoidable, unforeseen or accidental To set in place the resources, skills etc required for effective preventative and curative management.

Rehabilitate the land disturbed by the organisations activities in order to restore the land capability of the area Pay compensation to landowners for crop damage caused by chemical spills 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)

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)

6.2.3 a)

Surface water management 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

Impact Assessment and Project Appraisal March 2002

37

Linking EIA and environmental management systems

with the project activities. However, this layout is not user friendly for the o perational 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 activityaspectenvironmental 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 activityaspectimpact 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
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 Tecnolgicas, So 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 393405.

38

Impact Assessment and Project Appraisal March 2002