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To cite this article: Dr. Ross Marshall (2002) Developing environmental management systems
to deliver mitigation and protect the EIA process during follow up, Impact Assessment and
Project Appraisal, 20:4, 286-292
Professional practice
Ross Marshall
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I
Developmental projects are dynamic in the man- N THE FORMAL ASSESSMENT of develop-
ner in which proponents react to issues or events ment acceptability, comprehensive mitigation
arising during the conceptual planning, design proposals in an environmental statement (ES)
or construction phases. The basic challenge of can reduce opposition and assist a developers ap-
integrating environmental impact assessment proval process. Good practice presented in the UKs
Department of the Environment, Transport and Re-
(EIA) into an existing environmental manage-
gions (DETR) guidance document recommends that
ment system (EMS) is to provide adequate con- an applicant for development approval clearly out-
trol while allowing flexibility to cope with site- line commitment to the adoption of proposed mitiga-
specific project requirements. Environmental tion measures (DETR, 1997). This is sound advice,
management plans (EMP) are one way of con- but the guide gives little practical advice on how this
trolling the environmental effects of construction is to be achieved.
projects. These contain project-specific protocols As a utility company, with licensed responsibility
that act as an EMS interface between the EIA for maintaining electrical transmission and distribu-
and subsequent project planning and develop- tion systems within Scotland, England and Wales,
ment phases. This paper developed from the EIA ScottishPowers PowerSystems division (SP Power-
follow-up session of IAIA 2001 in Cartagena, Systems) continually seeks planning consents and
Columbia outlines the framework for an EMP licences within these geographic boundaries. There
is commercial benefit to SP PowerSystems in being
and its application in respect of the development
recognised as a clear deliverer of agreed mitigation
of an electrical infrastructure project within the proposals. Little commercial gain can be expected
UK. from reneging on mitigation, if it is likely to result in
a lessening in relations between the company and
decision-making bodies.
Keywords: environmental impact assessment; environmental
management; mitigation; EIA follow up; project
management; energy
Linking EIA to EMS
286 1461-5517/02/040286-7 US$08.00 IAIA 2002 Impact Assessment and Project Appraisal December 2002
Developing environmental management systems
and the conditional requirements of the operational scoping of significant environmental aspects is in-
licences it holds. Driven by increasing media atten- ternal, with the organisation itself determining sig-
tion, greater awareness of sustainable development, nificance, albeit within the framework of compliance
the need to be ahead of future prescriptive and puni- and continual improvement.
tive environmental legislation, reduced public accep- In EIA, decision-making bodies make decisions
tance of pollution and the ever-present threat of concerning the overall environmental acceptability
liability, most companies have voluntarily developed of a proposal, usually after a period of public consul-
their EMS in line with the international standards, tation. Any decisions resulting from the EMS are
BS EN ISO 14001 or the European Unions Eco specific to the businesss objectives and the aims of
Management and Audit Scheme (EMAS), or are the organisation controlling the system.
planning to do so (Marshall et al, 2001). In practice, EIA demands management structures
Recently, recognition of the manner in which envi- to implement the conclusions that arise from its
ronmental impact assessment (EIA), mitigation im- processes. By itself, the EIA process is not equipped
plementation and EIA follow up need to be to execute such actions. On the other hand, the EMS
performed, coupled with a desire to prove mitigation process is primarily a proactive management tool
objectiveness and to demonstrate clearly that all plan- sensitive to the existing environmental effects of
ning or consent conditions have been complied with, operations and easily adapted to control risk or in-
has encouraged SP PowerSystems to reassess the role corporate enacting procedures.
of existing EMS systems. Traditionally concerned
with the day-to-day running of operational activities, Environmental management plans
the management controls exerted by the EMS are
increasingly being adapted and applied within EIA. New developmental projects are dynamic in the
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Development of procedures setting out the EIA environmental obligations, expectations, consent
and site/route identification methodologies. conditions or mitigation strategies through to con-
Restructuring existing protocols for EIA. tractors involved in construction, infrastructure
Clarifying the regulatory structures and decision- maintenance or decommissioning projects.
making strategies that trigger a formal EIA, as Setting in place structures that link EIA to key
opposed to projects where an EIA is undertaken performance indicators designed to enhance over-
voluntarily. all business performance.
Development of procedures for formal EIA under Setting up structures that monitor and audit not
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specific regulatory or land-use planning systems. only performance within EIA, but also its down-
Developing audit trails between the EIA and EMS stream links into construction programmes, regu-
systems. latory compliance, mitigation performance and
Ensuring that the findings of the EIA process are verification of residual effect.
passed directly through to colleagues who are Linkage to tenders, contract agreements, the
operating in design, construction and ultimately Construction Design and Management (CDM)
operation. Regulations 1994, environmental management
Developing management links to transfer plans, planning and regulatory consents, and so on.
Parameter Information
Introduction Project description, commitment to mitigation implementation and consent fulfilment during construction
phase.
Generic environmental Reference to the standard documents contained within the SP PowerSystems ISO14001 EMS relating to
actions construction activities, waste management, control of contractors, and so on.
Environmentally significant The procedure, protocol and consultation process to be followed when environmentally significant changes to
changes the project design are encountered and potential amendments to the EMP are required. Identification of
responsibility for overseeing the changes to the EMP and ensuring that these changes do not conflict with any
consenting or planning conditions.
Project team roles and The role of the individual project team members is defined. Information should include their name, title,
responsibilities affiliation (that is, staff, contractor or environmental consultant), specific on-site responsibilities, and
environmental and auditing duties. The project manager is ultimately responsible for ensuring that the EMP is
adequately translated into contract documents and adhered to during all phases of the project.
Liaison and consultation Details and contact addresses for required liaison between the project team and the relevant external
requirements consultees and authorities to ensure that environmental issues are fully resolved.
Consents and permissions A record of required environmental licences and permissions prior to the start of construction.
Site-specific environmental A table of site-specific environmental actions of significance to the project, that is, mitigation commitments
actions and consenting conditions. Each condition is uniquely identified and grouped chronologically or according to
its specific environmental receptor (for instance, nature conservation, noise). The action required is listed.
Columns are included to allow for a cross-reference of EMP actions with consent conditions or proposed
mitigation actions and with contract document clauses. A column is included for the individual actions to be
signed off upon successful completion.
Changes during A register of variations records details of changes and environmental implications, linked to a variation
construction document appended to the EMP as a controlled document.
Monitoring programme Details and schedules of monitoring equipment calibration responsibilities.
Appendices Variation documents, key contacts, audit schedules and findings, waste management duty of care register.
Continual improvement is a key element of EMS. It conductors. On the basis of its experience with the
is unlikely, given the time-scales of individual ScottishIrish Interconnectors Mitigation Handbook
development projects, that this could take place. (ScottishPower, 2000), the smaller scale of this pro-
However, organisations that are involved in several ject and the recent certification of the company to
similar development projects should be able to show ISO14001, the company decided to develop an EMP
that project EMPs have led to improvements within specific to the project proposed.
the core EMS over time.
Environmental management plan The EMP system
in this, and other construction projects now operating
EIA follow up in SP PowerSystems, is dedicated to the project man-
agement, monitoring and audit of agreed mitigation
In setting linkage between the mitigation proposed strategies, and the verification of predicted environ-
and the final consenting conditions, it is on the obli- mental effects identified through EIA. The concept of
gation of the developing party to ensure that: EMP was promoted initially for significant works un-
dertaken on behalf of bodies such as the World Bank
mitigation proposals such as bunds, landscaping, (1991). The model for EMP adapted by SP PowerSys-
mounds or drainage systems, are identifiable in tems, however, has its origins in a 1999 proposal
plans associated with the planning application; document promoted by the UKs Environment
all physical measures are represented in plans or Agency for use in their flood defence programme
timetables and are presented at the scale necessary (Environment Agency, 1999). The perceived benefits
to ensure that mitigation will be effectively that SP PowerSystems identifies in EMPs are:
achieved;
all relevant mitigation measures are presented and the encouragement of a systematic and explicit
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identified as aspects of approval that the devel- approach to the controlled amelioration of envi-
oper would be willing to have included in the ronmental effects;
final consenting documentation; the clear identification of management and con-
mitigation proposals material to the applications tractual responsibilities;
acceptance, but which cannot be verified until the the integration of mitigation measures into the
onset of further detailed design or on the return of construction programme;
contractors tenders, have some form of timetable the integration of environmental planning consent
and consultation with relevant stakeholders to en- conditions into the construction programme;
sure their acceptance as a prerequisite to devel- auditable programmes addressing a key aspect of
opment progression; and environmental compliance;
a management structure is identified to demon- the means of demonstrating compliance with con-
strate what form of follow-up audit or verification sent conditions by decision-making bodies and
procedure is anticipated to ensure that proposed other stakeholders; and
mitigation or consented conditions will be enacted a means of engaging stakeholders in constructive
in accordance with the final consent for develop- dialogue during projects.
ment or planning permission.
An added advantage of EMPs is that, for the responsi-
In respect of the final bullet point, the following sec- ble engineers, they are not prescriptive; allowing the
tions of this paper outline the procedural approaches initiative to remain with the project manager, while
developed by SP PowerSystems in relationship to a ensuring that controls are instigated for activities that
transmission project in Scotland (Marshall, 2001). have the potential for environmental risk, regulatory
infringement and overall community relations.
Fife 132 kV system refurbishment
Outline framework for SP PowerSystems EMPs
Project outline and need SP PowerSystems planned
to refurbish and upgrade a 132kV transmission sys- The EMP is intended to be the interface between the
tem in Northeast Scotland, securing electricity sup- ES and the granting of planning consent for the sub-
plies for approximately 160,000 customers over the sequent engineering project phases such as:
next 40 years. The scheme involved dismantling 38
kilometres of overhead line, re-conductoring 88 detailed design;
kilometres of overhead line, modernising associated contract documentation;
substation equipment and replacing 22 kilometres of construction; and
overhead line and life-expired towers. operation.
Mitigation measures The ES for the project identi- The creation of the EMP starts either during the ini-
fied significant environmental impacts typically as- tial phases of a generic construction project or, in the
sociated with the construction of new overhead case of the Fife 132 kV refurbishment project, once
systems and the dismantling of old towers and the mitigation measures or consenting conditions
have been identified through EIA or within the plan- achievement criterion met. Finally, a column for
ning conditions. notes and recommended further actions is provided.
The objective of the EMP is to provide a contin-
ued link between EIA, consented conditions, the
initial environmental appraisal and SP PowerSys- Discussion and conclusions
tems environmental policies or initiatives, as well
as making explicit to all interested parties the For many companies, EIA now acts as an important
requirement for translation of these findings and pre-construction planning exercise in which design
polices into contract documents and working strat- attributes, site and routing strategy, and mitigation
egies. The core information is taken either directly concepts are closely examined prior to finalised de-
from the ESs mitigation chapters or the consenting sign and project costing. When moving forward
conditions of the final planning consent. This places from the planning and consenting phases into the
the EMP in context rather than repeating the full formal construction phase, it is thus important that
description given in such documents. the design commitments that mitigated environ-
Table 2 outlines the form and structure of a typi- mental effects and assisted in the gaining of consent
cal EMP (SP PowerSystems, 1999). are carried into practice.
For a responsible developer, the follow up of pre-
Table of site-specific environmental actions dicted mitigation requirements needs commitment
and careful management. The case study presented
A table of site-specific environmental actions forms above demonstrates that mitigation linkage can be
the core of the EMP procedures and is the central achieved through a simple management framework,
component of the plan. Depending on the scale of flexible in design but meeting a variety of anticipated
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Table 3. SP PowerSystems template for the table of site-specific environmental actions with hypothetical entries
to control the quality of EIA provides yet another Marshall, R (2001), Mitigation linkage: EIA follow up through the
application of EMPs in transmission construction projects, pa-
means by which successful companies can lead from per presented at IAIA 01 Impact Assessment in the Urban
the front. EIA is only successful as a management Context, EIA Follow up: Outcomes and Improvements Work-
technique when its findings are incorporated into the shop, 26 May1 June, Cartagena, Colombia, published on
CD-ROM: EIA Follow-up Workshop (Environment Canada,
business-making processes of the company. Suc- Hull, Canada).
cessfully integrated within the EMS structures of a Marshall, R, N Smith and R Wright (2001), A new challenge for
company, the findings and conclusions of the EIA industry: integrating EIA within operation EMS, paper pre-
sented at IAIA 01 Impact Assessment in the Urban Context
can be transferred into action. EIA Follow-up: Outcomes and Improvements Workshop, 26
May1 June, Cartagena, Columbia, published on CD-ROM,
EIA Follow-up Workshop (Environment Canada, Hull Canada).
ScottishPower (2000), Scotland Northern Ireland Interconnector:
References Construction Conditions Handbook Coylton Substation, 27%
kV Overhead Line and Associated Works (ScottishPower plc).
DETR, Department of the Environment, Transport and the SP PowerSystems (1999), Construction projects: environmental
Regions (1997), Mitigation Measures in Environmental State- guidance and construction of an environmental management
ments (HMSO, London). plan, ScottishPower, June.
Environment Agency (1999), Environmental Action Plans Good World Bank (1991), Annex C Operational Directive 4.01
Practice Guidelines (Anglia Region). Environmental Assessment (World Bank, Washington DC).
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