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AN ALTERNATING-SEQUENCE CONCEPTUAL
FRAMEWORK FOR EIA-EMS INTEGRATION
ANASTÁSSIOS PERDICOÚLIS
Department of Biological and Environmental Engineering
University of Trás-os-Montes and Alto Douro
Vila Real 5001-801, Portugal
tasso@utad.pt
BRIDGET DURNING
Oxford Institute for Sustainable Development
School of the Built Environment
Oxford Brookes University
Gipsy Lane, Oxford OX3 0BP, United Kingdom
bdurning@brookes.ac.uk
Introduction
The integration of Environmental Impact Assessment (EIA) and Environmental
Management Systems (EMS) has been approached several times in recent academic
literature, and most indications about its feasibility are favourable and encouraging.
This article reviews existing conceptual frameworks and individual issues raised
in the literature regarding the integration and, based on them, recommends a new
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Overview
EIA and EMS are both concerned with the environmental effects of development
projects, although they came into existence from different origins. The two processes
also currently have different legal and standardisation status (Eccleston and Smythe,
2002).
Since the 1999 International Association for Impact Assessment (IAIA) confer-
ence in Scotland, the link between EIA and EMS has received certain attention in the
academic literature (Sheate, 1999). Consideration of this particular link, together
with that of other “environmental” tools, has also been encouraged to a certain
extent through workshops in subsequent IAIA conferences — e.g., 2002, in The
Netherlands (Sheate, 2002).
A number of researchers in published work provide general points of encour-
agement, or even more concrete contributions, towards the integration of EIA and
EMS. For example, Barnes and Lemon (1999) provide a successful example of
an EIA-EMS link from the early 1990s — i.e., before the publication of the first
international EMS standard, ISO 14001:1996. Their case study included produc-
tion of an Environmental Management Plan (EMP), which is prepared at the same
time as EIA and intended to address the mitigation measures required for the
construction and operation stages of the project. Barnes and Lemon propose that
one of the benefits of the combined practice is the production of a more detailed
Environmental Impact Statement (EIS) with combined environmental management
information. Furthermore, they suggest as further benefits that the EIA-EMS inte-
gration allows the EIA process to focus on critical environmental aspects and solu-
tions while the EMS can focus on more detailed and technical issues (e.g., dust
suppression).
Also at an “early” stage in the literature, but shortly after the publication of
the ISO 14001:1996 standard and looking at the benefit of EIA to EMS devel-
opment, Ridgway (1999) identified that the non user-friendly format of EISs (the
EIA report) does not readily assist in the development of EMSs for the subse-
quent operational phase of a development. In particular, the all-important (to the
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State-of-the-Art
The most significant contributions concerning EIA-EMS integration come from few
articles (Eccleston and Smythe, 2002; Sánchez and Hacking, 2002; Ridgway, 1999
and 2005). Their approaches are presented in more detail in the following section.
The contributions are made at two levels: a higher, conceptual level, and a lower,
specific issue-focused level.
Approaches
Relevent literature reveals three approaches to EIA-EMS integration, although
whilst the Eccleston and Smythe (2002) approach is a proper conceptual frame-
work, the other two contributions (Sánchez and Hacking, 2002; Ridgway, 1999 and
2005) merely offer ideas about possible link configurations and tools.
Eccleston and Smythe (2002) propose a single-sequence conceptual framework
for the EIA-EMS integration (Fig. 1), in which EIA is leading in the first phases
and EMS is leading in the later phases.
Sánchez and Hacking (2002) offer another single-sequence idea for the EIA-
EMS integration (Fig. 2), quite similar to the Eccleston and Smythe proposal.
Ridgway presents a set of generic phases for projects, for which various environ-
mental tools are identified (Ridgway, 1999). Thus, EIA and EMS are encountered as
protagonists in different phases of the project life (Fig. 3). Although it is not meant
to be a conceptual framework for EIA-EMS integration, the scheme indicates a
possible alternating sequence of “environmental tools” — e.g., EIA-EMS-EIA.
Specific issues
Besides the higher-level conceptual frameworks detailed in the literature, the key
articles also reveal a number of medium- to low-level specific issues that are
less abstract and which help to refine the perspective of EIA-EMS integration.
These are:
(i) Environmental aspects are an exclusive feature of EMS, even though the
notion itself is not presented very clearly in the ISO 14001 standard (ISO,
2004). Sánchez and Hacking (2002) interpret environmental aspects as the
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Fig. 1. Eccleston and Smythe’s single-sequence conceptual framework for the EIA-EMS integration;
adapted from Eccleston and Smythe (2002).
“causal mechanism” that stands between the action (cause) and end result
(effects, change, or impact), which hints to a relatively easy link with the
EIA practice.
(ii) The static and rather non-clear presentation nature of EISs does not provide
a natural link with the EMS documents (Ridgway, 2005), which hints to the
necessity for transformation work in the EIS construction and format.
(iii) The significance of impacts is treated differently in the two processes: explicitly
in EIA, and vaguely in the ISO 14001 EMS standard (Eccleston and Smythe,
2002). This is a particularly low-level issue, but uniformity is important for
the process integration.
(iv) The varied (i.e., non-standard) EIA process methodology contrasts with the
standards of EMS (ISO, 2004; EC, 2001). Besides the high-level issue of the
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Fig. 2. Sánchez and Hacking’s single-sequence idea for the EIA-EMS integration; based on Sánchez
and Hacking (2002) highlighting the EMS structure.
Fig. 3. Ridgway’s project phases and main environmental tools; adapted from Ridgway (1999).
January 28, 2008 15:18 WSPC/154-JEAPM 00286
conceptual framework treated in this article, this contrast may give rise to
lower-level issues such as non-uniformity in notions and terminology.
(v) The legal status of the two processes is different: EMS is a voluntary scheme,
while EIA is a legal requirement is many countries. The lack of a common legal
status is a higher-level issue of compatibility, as common status would give
more stability and credibility to the integration. In addition, the legal status
issue extends to more detailed procedural issues, such as the environmental
compliance requirement (Eccleston and Smythe, 2002).
(vi) The in-house versus consultant-based process of execution interferes with the
integration and has been identified as a hindering factor (Sánchez and Hacking,
2002).
(vii) Several other process steps, such as scoping, impact assessment, and public
participation, are treated only in EIA but could also benefit the EMS practice
(Eccleston and Smythe, 2002).
Framework
The new conceptual framework which harmonises the sequence of responsibilities
between the EIA and EMS processes is presented in Fig. 4 and features an alternating
sequence of EIA and EMS steps.
Starting with EMS, and specifically with the environmental policy, the frame-
work gives a “top-down” character to the process. It begins with the project proposal
(with detailed specifications) being drafted during the planning phase in accordance
with the environmental policy.
The switch to EIA occurs when the project proposal, incorporating an envi-
ronmental management programme for each phase of the project, is completed.
This extended project proposal is then subject to the EIA process more-or-less as it
currently exists, until a decision is obtained from the authorities.
A switch-back to EMS occurs with the approval of the project proposal (incor-
porating the environmental management programme), which can subsequently be
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Fig. 4. The proposed alternating-sequence conceptual framework for the EIA-EMS integration, with
key documents of both processes.
developed into a proper EMS. The process then loops into the continuous improve-
ment circle (ISO, 2004) of an operational EMS.
As suggested in the framework derived from Ridgway contained in Fig. 3, the
decommissioning phase of the project would be the jurisdiction of the EIA process,
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so a return to EIA can be also added to our conceptual framework for when the
project has reached the end of its lifetime.
Finally, although this is not shown in the conceptual framework in Fig. 4, a
separate loop back to EIA would provide feedback to the EIA team regarding their
impact forecasting capabilities, which provides the possibility for improvement in
future applications.
Document modifications
In order for this framework for EIA-EMS integration to be implemented, some
modifications in the role and/or content of key documents of both processes would
be needed. For reasons cited previously due to variation in EIA practice these are
described at a medium level of detail:
(a) The initial environmental review (ISO, 2004; Cagno et al., 1999) would
serve as a precursor of the baseline study of the EIS (hereby called “impact
statement”).
(b) The project proposal, usually prepared before the EIA begins, would include an
executable environmental management programme for all phases of the project,
as per EMS specifications.
(c) The impact statement would pay due attention to all phases, and include an
aspects analysis to bridge with EMS.
(d) The decision or approval of the project proposal would include summaries of
the environmental management programme — eventually with modifications.
(e) The EMS documents, in addition to their main role, would also feed back into
the EIA team’s knowledge-base and know-how.
Discussion
Implications
Our framework would have a number of consequences for how both the EIA and
EMS processes are undertaken. For EIA, the recommendations presented in the
previous section imply the following consequences:
(a) the project proposal will have to follow a proper and formal environmental
policy and planning procedure, as per EMS specifications;
(b) the project proposal will contain a management programme for all project
phases;
(c) the impact assessment will include environmental aspects analysis (Sánchez
and Hacking, 2002), and will give due importance to all phases of the project;
(d) the decision/approval will end up with a complete document, out of which an
EMS could be readily established;
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(e) after some time of the project operation, the EMS could feed back into the EIA
team about the real environmental impacts; thus, the EIA team could improve
its impact forecasting precision.
For EMS, the recommendations presented in the previous section imply the
following consequences for the process:
(a) the first two phases, environmental policy and planning, would be as in any
EMS process, except there is no project in operation yet (it would have to
be hypothesised or drafted based on experience of similar operations with the
sector);
(b) the next two phases following EMS planning would be the “EIA module”;
(c) following the successful conclusion of the “EIA module”, implementation (of
the project and the environmental policy) and operation occur;
(d) after the first full EMS cycle of implementation-audit-review, the “EIA module”
would not be necessary in any continuing cycles, and the EMS would proceeds
normally throughout the operation phase;
(e) decommissioning would be considered in both the EMS-EIA documentation at
the terminal phase of the project.
Global assessment
By alternating the steps of the two processes in an A-B-A(-B) model, the proposed
framework would bring a closer collaboration between the professionals involved
in implanting EIA and EMS. Simpler links of the A-B type are likely to support
more superficial relationships, with “finish and exit” attitudes.
The inter-twining of the tasks between the two processes also gives a more
uniform approach to environmental impacts of projects, dealing with them in a single
framework before, during, and after the development. Eventually, the alternating-
sequence framework may be capable of producing a proper thinking and integrated
attitude about environmental impacts, instead of maintaining separate treatment by
different professionals (of EIA and EMS, to mention the least).
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Technical assessment
Some technical innovations of the framework invite some reflections. To begin
with, the initial environmental review (IER) is given a new role and responsibil-
ity, namely to serve as a precursor of the baseline study of the impact statement.
The baseline study of the impact statement should then be in accordance with
the IER. This new role of the IER also implies a flexible scope: site-specific but
with extensibility to wider issues approached in EIA (e.g., cumulative effects, sus-
tainability indicators). Finally, the IER also provides an opportunity to introduce
environmental aspects and define the way that they will be used later in the impact
statement.
Major innovations in the impact statement include environmental aspects and
the environmental management programme (EMPg). Such provisions are capable
of improving the image of EISs as non-user friendly and bureaucratic documents,
as well as being non-usable in EMS (see, for instance, Ridgway, 1999 and Sánchez
and Hacking, 2002). Technical solutions to the above innovations are expected to be
given in case-by-case applications, recruiting the capacity and experience of both
EIA and EMS professionals.
Future work
The next step following the conceptual framework is its experimental implementa-
tion. Resolution of the specific issues rests with the EIA and EMS practitioners, in
per-country application cases. Reflections on more general methodological issues,
and potentially refinement of the framework, will be possible only after collective
experience of several applications.
Conclusions
With respect to the integration of EIA with EMS, the new alternating-sequence
conceptual framework, EMS-EIA-EMS(-EIA) presented in this article, provides
a balanced division of tasks. This framework includes a series of modifications
to key documents of both processes, to render them appropriate for smooth
integration.
Institutional issues of the EIA-EMS integration, such as a common legal status
of both processes, appear to be the object of national deliberations. Methodological
(or technical) issues of the EIA-EMS integration, such as the environmental aspects,
can be (and are being) treated at a more detailed level of attention by the scientific
community. The most important of these specific issues have been identified, and
future research is likely to give satisfactory answers.
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Acknowledgements
In the preparation of this article, the first author wishes to express his gratitude to
the Fundação para a Ciência e Tecnologia (FCT) of the Portuguese government for
their financial support to his 2005–2006 sabbatical leave, and to the School of the
Built Environment/ Oxford Institute for Sustainable Development at Oxford Brookes
University for their warm reception in a world-class academic environment.
References