Impact Assessment and Project Appraisal

ISSN: 1461-5517 (Print) 1471-5465 (Online) Journal homepage: http://www.tandfonline.com/loi/tiap20

Developing environmental management systems

to deliver mitigation and protect the EIA process
during follow up

Dr. Ross Marshall

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

To link to this article: http://dx.doi.org/10.3152/147154602781766618

Published online: 20 Feb 2012.

Submit your article to this journal

Article views: 407

View related articles

Citing articles: 6 View citing articles

Full Terms & Conditions of access and use can be found at

http://www.tandfonline.com/action/journalInformation?journalCode=tiap20

Download by: [39.48.155.49] Date: 17 January 2016, At: 19:16

 Impact Assessment and Project Appraisal, volume 20, number 4, December 2002, pages 286292, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK
Professional practice
Developing environmental management systems
to deliver mitigation and protect the EIA
process during follow up
Ross Marshall
Downloaded by [39.48.155.49] at 19:16 17 January 2016
Developmental projects are dynamic in the man-
ner in which proponents react to issues or events
arising during the conceptual planning, design
or construction phases. The basic challenge of
integrating environmental impact assessment
(EIA) into an existing environmental manage-
ment system (EMS) is to provide adequate con-
trol while allowing flexibility to cope with site-
specific project requirements. Environmental
management plans (EMP) are one way of con-
trolling the environmental effects of construction
projects. These contain project-specific protocols
that act as an EMS interface between the EIA
and subsequent project planning and develop-
ment phases. This paper developed from the EIA
follow-up session of IAIA 2001 in Cartagena,
Columbia outlines the framework for an EMP
and its application in respect of the development
of an electrical infrastructure project within the
UK.
Keywords: environmental impact assessment; environmental
management; mitigation; EIA follow up; project
management; energy
Dr Ross Marshall is the Environment Planning Manager, SP
PowerSystems, ScottishPower, New Alderston House, Dove
Wynd, Strathclyde Business Park, Bellshill, ML4 3FF, Scotland;
Tel: +44 1698 413273; E-mail: ross.marshall@
SPPowerSystems.com
286 1461-5517/02/040286-7 US$08.00 IAIA 2002
I
N THE FORMAL ASSESSMENT of develop-
ment acceptability, comprehensive mitigation
proposals in an environmental statement (ES)
can reduce opposition and assist a developers ap-
proval process. Good practice presented in the UKs
Department of the Environment, Transport and Re-
gions (DETR) guidance document recommends that
an applicant for development approval clearly out-
line commitment to the adoption of proposed mitiga-
tion measures (DETR, 1997). This is sound advice,
but the guide gives little practical advice on how this
is to be achieved.
As a utility company, with licensed responsibility
for maintaining electrical transmission and distribu-
tion systems within Scotland, England and Wales,
ScottishPowers PowerSystems division (SP Power-
Systems) continually seeks planning consents and
licences within these geographic boundaries. There
is commercial benefit to SP PowerSystems in being
recognised as a clear deliverer of agreed mitigation
proposals. Little commercial gain can be expected
from reneging on mitigation, if it is likely to result in
a lessening in relations between the company and
decision-making bodies.
Linking EIA to EMS
Business-orientated environmental management sys-
tems (EMS) have developed in direct response to
increasing internal and external awareness of envi-
ronmental risk, the need to demonstrate proof that a
business is in control of its environmental aspects
Impact Assessment and Project Appraisal December 2002

and the conditional requirements of the operational
licences it holds. Driven by increasing media atten-
tion, greater awareness of sustainable development,
the need to be ahead of future prescriptive and puni-
tive environmental legislation, reduced public accep-
tance of pollution and the ever-present threat of
liability, most companies have voluntarily developed
their EMS in line with the international standards,
BS EN ISO 14001 or the European Unions Eco
Management and Audit Scheme (EMAS), or are
planning to do so (Marshall et al, 2001).
Recently, recognition of the manner in which envi-
ronmental impact assessment (EIA), mitigation im-
plementation and EIA follow up need to be
performed, coupled with a desire to prove mitigation
objectiveness and to demonstrate clearly that all plan-
ning or consent conditions have been complied with,
has encouraged SP PowerSystems to reassess the role
of existing EMS systems. Traditionally concerned
with the day-to-day running of operational activities,
the management controls exerted by the EMS are
increasingly being adapted and applied within EIA.
Downloaded by [39.48.155.49] at 19:16 17 January 2016
Practicalities of bringing EIA into EMS
EIA is both an evaluation technique and a regulatory
process associated with land-use planning systems.
Its methodology follows previously developed
national or organisational models. EMS has no statu-
tory basis, representing only a companys willing-
ness to adopt a system of management that considers
and balances environmental aspects. However, EMS
do provide systems that track and highlight legisla-
tive requirements. While the EIA process is anticipa-
tory in its prediction of adverse effect, the true scale
of which can only be monitored after development
has occurred, an EMS is reactive, with adverse ef-
fect predictions being made on the basis of observed
or monitored data.
While both systems have the objective of reduc-
ing environmental impacts, it may be erroneous to
consider the two systems as directly comparable.
The scoping of key environmental issues and ulti-
mately the decision-making process provides notable
case points. In EIA, the scoping process is primarily
external with identified aspects being developed
through consultation with external organisations,
individuals and statutory bodies. In EMS, the
Table 1. Perceived role and objective of environmental management plans
EIA Environmental management plans
Identification of environmental responsibilities for the company and its
contractor(s).
Predictive and Setting of project specific objectives and targets during construction
anticipatory (and operation).
processes
Setting of project specific environmental control procedures.
In-situ rapid reaction to site conditions or emergencies
Impact Assessment and Project Appraisal December 2002
Developing environmental management systems
scoping of significant environmental aspects is in-
ternal, with the organisation itself determining sig-
nificance, albeit within the framework of compliance
and continual improvement.
In EIA, decision-making bodies make decisions
concerning the overall environmental acceptability
of a proposal, usually after a period of public consul-
tation. Any decisions resulting from the EMS are
specific to the businesss objectives and the aims of
the organisation controlling the system.
In practice, EIA demands management structures
to implement the conclusions that arise from its
processes. By itself, the EIA process is not equipped
to execute such actions. On the other hand, the EMS
process is primarily a proactive management tool
sensitive to the existing environmental effects of
operations and easily adapted to control risk or in-
corporate enacting procedures.
Environmental management plans
New developmental projects are dynamic in the
manner in which planners react to issues or events
arising during the conceptual planning, design or con-
struction phases. The basic challenge of integrating
EIA into an existing EMS is to provide adequate con-
trol while allowing flexibility to cope with the dynam-
ics and requirements of a particular development
project. Environmental management plans (EMP) are
one way of controlling the environmental effects of
construction projects; these contain project-specific
protocols that act as an EMS interface between the
EIA and subsequent project planning and develop-
ment phases (Environment Agency, 1999).
EIA can identify project specific environmental
effects and the need for environmental controls. It
would not be practical or necessary to greatly amend
the core EMS to provide the necessary controls, as
these effects may be short lived, transitory or spe-
cific to a particular site affected by development. It
would be necessary, however, to create documented
links between the core EMS and EIA/EMP pro-
cedures. In such situations, project-specific EMP can
have a number of benefits.
Table 1 shows a simplified model of a project-
specific EMP. The key to its success is the develop-
ment of strong linkages and practical interfaces
between the core EMS and the project-specific EMP.
Construction and
operation
Reactive operational
procedures
287
 Developing environmental management systems

Table 2 expands on these interactions, outlining a

more complex model aimed at documenting and
controlling the implementation of new development Continual improvement is a key
through the existing core EMS. The objective is to element of EMS: organisations that
execute mitigation or controls identified through are involved in several similar
EIA or planning consent in accordance with the ap-
proach set by the policy and objectives of the core development projects should be able to
EMS. The project-specific EMP will encompass site show that project EMPs have led to
operations, the responsibilities of the company and
its contractors, specific training requirements and
improvements within the core EMS
documentation. In seeking to integrate EIA within over time
the overall structure of SP PowerSystems EMS, a
number of practical issues have required considera-
tion. These are:

Development of procedures setting out the EIA
and site/route identification methodologies.
Restructuring existing protocols for EIA.
Clarifying the regulatory structures and decision-
making strategies that trigger a formal EIA, as
opposed to projects where an EIA is undertaken
voluntarily.
Development of procedures for formal EIA under
Downloaded by [39.48.155.49] at 19:16 17 January 2016
environmental obligations, expectations, consent
conditions or mitigation strategies through to con-
tractors involved in construction, infrastructure
maintenance or decommissioning projects.
Setting in place structures that link EIA to key
performance indicators designed to enhance over-
all business performance.
Setting up structures that monitor and audit not

specific regulatory or land-use planning systems.
Developing audit trails between the EIA and EMS
systems.
Ensuring that the findings of the EIA process are
passed directly through to colleagues who are
operating in design, construction and ultimately
operation.
Developing management links to transfer
only performance within EIA, but also its down-
stream links into construction programmes, regu-
latory compliance, mitigation performance and
verification of residual effect.
Linkage to tenders, contract agreements, the
Construction Design and Management (CDM)
Regulations 1994, environmental management
plans, planning and regulatory consents, and so on.

Table 2. EMP structure and content

Parameter Information

Introduction
Generic environmental
actions
Environmentally significant
changes
Project team roles and
responsibilities
Liaison and consultation
requirements
Consents and permissions
Site-specific environmental
actions
Changes during
construction
Monitoring programme
Appendices
Project description, commitment to mitigation implementation and consent fulfilment during construction
phase.
Reference to the standard documents contained within the SP PowerSystems ISO14001 EMS relating to
construction activities, waste management, control of contractors, and so on.
The procedure, protocol and consultation process to be followed when environmentally significant changes to
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.
The role of the individual project team members is defined. Information should include their name, title,
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.
Details and contact addresses for required liaison between the project team and the relevant external
consultees and authorities to ensure that environmental issues are fully resolved.
A record of required environmental licences and permissions prior to the start of construction.
A table of site-specific environmental actions of significance to the project, that is, mitigation commitments
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.
A register of variations records details of changes and environmental implications, linked to a variation
document appended to the EMP as a controlled document.
Details and schedules of monitoring equipment calibration responsibilities.
Variation documents, key contacts, audit schedules and findings, waste management duty of care register.

288 Impact Assessment and Project Appraisal December 2002


Continual improvement is a key element of EMS. It
is unlikely, given the time-scales of individual
development projects, that this could take place.
However, organisations that are involved in several
similar development projects should be able to show
that project EMPs have led to improvements within
the core EMS over time.
EIA follow up
In setting linkage between the mitigation proposed
and the final consenting conditions, it is on the obli-
gation of the developing party to ensure that:
mitigation proposals such as bunds, landscaping,
mounds or drainage systems, are identifiable in
plans associated with the planning application;
all physical measures are represented in plans or
timetables and are presented at the scale necessary
to ensure that mitigation will be effectively
achieved;
all relevant mitigation measures are presented and
Downloaded by [39.48.155.49] at 19:16 17 January 2016
identified as aspects of approval that the devel-
oper would be willing to have included in the
final consenting documentation;
mitigation proposals material to the applications
acceptance, but which cannot be verified until the
onset of further detailed design or on the return of
contractors tenders, have some form of timetable
and consultation with relevant stakeholders to en-
sure their acceptance as a prerequisite to devel-
opment progression; and
a management structure is identified to demon-
strate what form of follow-up audit or verification
procedure is anticipated to ensure that proposed
mitigation or consented conditions will be enacted
in accordance with the final consent for develop-
ment or planning permission.
In respect of the final bullet point, the following sec-
tions of this paper outline the procedural approaches
developed by SP PowerSystems in relationship to a
transmission project in Scotland (Marshall, 2001).
Fife 132 kV system refurbishment
Project outline and need SP PowerSystems planned
to refurbish and upgrade a 132kV transmission sys-
tem in Northeast Scotland, securing electricity sup-
plies for approximately 160,000 customers over the
next 40 years. The scheme involved dismantling 38
kilometres of overhead line, re-conductoring 88
kilometres of overhead line, modernising associated
substation equipment and replacing 22 kilometres of
overhead line and life-expired towers.
Mitigation measures The ES for the project identi-
fied significant environmental impacts typically as-
sociated with the construction of new overhead
systems and the dismantling of old towers and
Impact Assessment and Project Appraisal December 2002
Developing environmental management systems
conductors. On the basis of its experience with the
ScottishIrish Interconnectors Mitigation Handbook
(ScottishPower, 2000), the smaller scale of this pro-
ject and the recent certification of the company to
ISO14001, the company decided to develop an EMP
specific to the project proposed.
Environmental management plan The EMP system
in this, and other construction projects now operating
in SP PowerSystems, is dedicated to the project man-
agement, monitoring and audit of agreed mitigation
strategies, and the verification of predicted environ-
mental effects identified through EIA. The concept of
EMP was promoted initially for significant works un-
dertaken on behalf of bodies such as the World Bank
(1991). The model for EMP adapted by SP PowerSys-
tems, however, has its origins in a 1999 proposal
document promoted by the UKs Environment
Agency for use in their flood defence programme
(Environment Agency, 1999). The perceived benefits
that SP PowerSystems identifies in EMPs are:
the encouragement of a systematic and explicit
approach to the controlled amelioration of envi-
ronmental effects;
the clear identification of management and con-
tractual responsibilities;
the integration of mitigation measures into the
construction programme;
the integration of environmental planning consent
conditions into the construction programme;
auditable programmes addressing a key aspect of
environmental compliance;
the means of demonstrating compliance with con-
sent conditions by decision-making bodies and
other stakeholders; and
a means of engaging stakeholders in constructive
dialogue during projects.
An added advantage of EMPs is that, for the responsi-
ble engineers, they are not prescriptive; allowing the
initiative to remain with the project manager, while
ensuring that controls are instigated for activities that
have the potential for environmental risk, regulatory
infringement and overall community relations.
Outline framework for SP PowerSystems EMPs
The EMP is intended to be the interface between the
ES and the granting of planning consent for the sub-
sequent engineering project phases such as:
detailed design;
contract documentation;
construction; and
operation.
The creation of the EMP starts either during the ini-
tial phases of a generic construction project or, in the
case of the Fife 132 kV refurbishment project, once
the mitigation measures or consenting conditions
289
 Developing environmental management systems
have been identified through EIA or within the plan-
ning conditions.
The objective of the EMP is to provide a contin-
ued link between EIA, consented conditions, the
initial environmental appraisal and SP PowerSys-
tems environmental policies or initiatives, as well
as making explicit to all interested parties the
requirement for translation of these findings and
polices into contract documents and working strat-
egies. The core information is taken either directly
from the ESs mitigation chapters or the consenting
conditions of the final planning consent. This places
the EMP in context rather than repeating the full
description given in such documents.
Table 2 outlines the form and structure of a typi-
cal EMP (SP PowerSystems, 1999).
Table of site-specific environmental actions
A table of site-specific environmental actions forms
the core of the EMP procedures and is the central
component of the plan. Depending on the scale of
Downloaded by [39.48.155.49] at 19:16 17 January 2016
the project, the table of actions may be subdivided
into three project phases: before construction; during
construction; and following construction. For each
phase, a further subdivision by relevant environ-
mental impacts or aspects (such as water quality) is
possible.
Table 3 presents a template for a typical EMP. A
unique numerical identifier references each specific
action. For the Fife 132 kV refurbishment project, it
was decided to reference also the relevant section
numbers within the ES and the planning consent.
These references are followed by the objective of
the action, which should be one sentence. This
information assists the Project Engineer or contrac-
tor in understanding the reasons behind each
recommendation.
It is important that the action statements be clear
and concise, but they must be specific enough to
ensure the action is adequately translated into con-
tract documents and implemented correctly on site.
Responsibility for each action should be clearly
assigned to an individual or organisation to ensure
implementation.
The achievement or verification criteria by which
the successful completion of the environmental ac-
tion can be measured must be clearly stated. Where
practical, this target should be measurable, auditable
and time-related.
Columns in the EMP table are included to allow the
design engineer to record the contract references and
consent/mitigation references that incorporate each
environmental action. This can then be checked by SP
PowerSystems Project Manager or Environmental
Planning Engineer to ensure full inclusion. If the ac-
tion is not required in contract documents, it has be-
come common practice to shade out the column.
A column is available for actions to be signed off
as complete by the Resident Engineer or Project
Manager after the action has been carried out and
290
achievement criterion met. Finally, a column for
notes and recommended further actions is provided.
Discussion and conclusions
For many companies, EIA now acts as an important
pre-construction planning exercise in which design
attributes, site and routing strategy, and mitigation
concepts are closely examined prior to finalised de-
sign and project costing. When moving forward
from the planning and consenting phases into the
formal construction phase, it is thus important that
the design commitments that mitigated environ-
mental effects and assisted in the gaining of consent
are carried into practice.
For a responsible developer, the follow up of pre-
dicted mitigation requirements needs commitment
and careful management. The case study presented
above demonstrates that mitigation linkage can be
achieved through a simple management framework,
flexible in design but meeting a variety of anticipated
needs.
In seeking to formalise and ensure mitigation
follow up, EMPs have an important role to play in
post-consent and during construction. The EMP sys-
tem is flexible in its approach to specific forms of de-
velopment, and has the distinct advantage that, while
it forms a component of an ISO140001 certified EMS,
it is not so formalised and restricted in its approach to
the site-specific issues facing a development project.
It is in this area of EMS-lite systems that SP
PowerSystems now seeks to derive the greatest
benefit and control of adverse effects. The company
believes that, in seeking mitigation linkage between
the EIA and the construction phase, EMPs provide a
compact solution that is simple in design and man-
agement and complementary to other safety and
quality engineering programmes.
EMPs also have the advantage that they are
compatible with, and integrated within, the wider
corporate ISO 14001 environmental management
system. Thus, they increase their transparency with-
in an organisation and provide demonstrable proof to
regulatory bodies that environmental care has re-
mained a priority within the companys ethos and
governance.
In seeking to incorporate a specialist process such
as EIA into EMS, it is important to recognise that
the systems still have to remain practical, whilst al-
lowing operational control over the project. One of
the fascinating aspects of EIA is its flexibility; few
other methodologies can be adapted so readily to
wide ranging forms of development or perceptions
of environmental effect. No company can allow or
afford its EMS to stifle such initiative and ingenuity,
but equally it is to a companys advantage to demon-
strate through documented controls the decision-
making processes by which effects were evaluated,
mitigated and controlled.
Seeking to enhance the practical aspects of EMS
Impact Assessment and Project Appraisal December 2002
 Developing environmental management systems

Table 3. SP PowerSystems template for the table of site-specific environmental actions with hypothetical entries

No Objective Action Responsible Achievement Contract reference Consent/ Completed Notes

person criteria mitigation (initial and date) further action
reference

Actions during construction

Nature conservation
12 To avoid Vehicle movement Contractor No significant long- Doc 13F/2.3 EIS Ref. 3
disturbance should be restricted term damage to (sect 6.9)
to moorland to track or coarse moorland
Downloaded by [39.48.155.49] at 19:16 17 January 2016

grassland below the

moorland
13 Example Materials and traffic Contractor No evidence Doc 13F/2.4 Section 37
to be kept off Field of transport or Ref. No 3
A where green material movement
orchid resides
Landscape
14 To reduce visual Planting of Contractor Material evidence of EIS Ref. 6
effect at No 27 the screening belt complete planting (sect 11.7)
Larches along Wood Lane scheme
during construction
Water quality
15 To reduce risk to Installation of Site engineer Photograph of Section 37 Verification of oil
Middlemarch Burn oil protection boom in position Ref. No 13 spillage kit
floating boom presence

No Objective Action Responsible Achievement Contract Consent/ Completed Notes

person criteria Reference mitigation (initial and date) further action
reference

Actions during construction (including monitoring)

Recreation and amenity

34 To maintain Restricted Project No valid out- ES Ref. 7
the privacy of local working hours manager of-hours compliant (sect 10.3)
residents during
weekend
35 To reduce visual Lopping and re- Contractor Material evidence of Doc 13F/6.1 ES Ref. 6
effect at Crudville planting of trees at completed works (sect 11.8)
playing fields Crudville spinney

Impact Assessment and Project Appraisal December 2002 291

 Developing environmental management systems
to control the quality of EIA provides yet another
means by which successful companies can lead from
the front. EIA is only successful as a management
technique when its findings are incorporated into the
business-making processes of the company. Suc-
cessfully integrated within the EMS structures of a
company, the findings and conclusions of the EIA
can be transferred into action.
References
DETR, Department of the Environment, Transport and the
Regions (1997), Mitigation Measures in Environmental State-
ments (HMSO, London).
Environment Agency (1999), Environmental Action Plans Good
Practice Guidelines (Anglia Region).
Downloaded by [39.48.155.49] at 19:16 17 January 2016
292
Marshall, R (2001), Mitigation linkage: EIA follow up through the
application of EMPs in transmission construction projects, pa-
per presented at IAIA 01 Impact Assessment in the Urban
Context, EIA Follow up: Outcomes and Improvements Work-
shop, 26 May1 June, Cartagena, Colombia, published on
CD-ROM: EIA Follow-up Workshop (Environment Canada,
Hull, Canada).
Marshall, R, N Smith and R Wright (2001), A new challenge for
industry: integrating EIA within operation EMS, paper pre-
sented at IAIA 01 Impact Assessment in the Urban Context
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:
Construction Conditions Handbook Coylton Substation, 27%
kV Overhead Line and Associated Works (ScottishPower plc).
SP PowerSystems (1999), Construction projects: environmental
guidance and construction of an environmental management
plan, ScottishPower, June.
World Bank (1991), Annex C Operational Directive 4.01
Environmental Assessment (World Bank, Washington DC).
Impact Assessment and Project Appraisal December 2002