Guidelines for Standardised Environmental Management Plans

Draft guidelines for standardised EMP for DWAF projects (May 2002)

GUIDELINES FOR STANDARDISED ENVIRONMENTAL MANAGEMENT PLANS

FOR

DEPARTMENT OF WATER AFFAIRS

AND FORESTRY PROJECTS.

Prepared for:Department of Water Affairs and Forestry

Directorate: Social and Ecological Services

Prepared by:CSIR

Division of Water Environment and Forestry Technology

DATE:May 2002

1

Draft guidelines for standardised EMP for DWAF projects (May 2002)

Executive Summary

These guidelines for standardised Environmental Management Plans (EMPs) have been developed as part of the Department of Water Affairs and Forestry’s (DWAF) initiative to ensure that Integrated Environmental Management principles are implemented within the Department’s functions. The purpose of this initiative is to ensure compliance with environmental legislation and to promote sustainable environmental practice.

DWAF: Water Resource Management propose to standardise the EMPs that will be required by the new Integrated Environmental Management Regulations which are currently being developed by the Department of Environmental Affairs and Tourism. The EMPs will be produced by DWAF project managers in certain cases (in-house projects), or the contractors and their environmental consultants in other cases. Guidelines on what DWAF require in the EMPs will enable the efficient production of these plans. By standardising the EMPs, review and information finding within the plans will be made easier and the efficient monitoring of EMP implementation will be facilitated. These guidelines are therefore, applicable to all DWAF staff, specifically those involved in Water Resource Management, who:

• develop terms of reference for projects;

• approve project proposals from consultants;

• commission contracts with consultants; and
• monitor project implementation;

In addition, these guidelines are designed to assist those parties involved in the project implementation and operational phases of DWAF Water Resource Management funded projects. Relevant parties include the:

• project planning team;

• consulting engineers;
• contractorsandsub-contractors;
• environmental consultants and sub-consultants and
• affected parties.

The guidelines begin by providing basic background information on Integrated Environmental Management in DWAF as well as the current and expected legislation requiring the implementation of EMPs. Then information on generic guidelines for the development of an EMP, as required by DWAF, is provided. This chapter provides a brief explanation of each of the sections that should be included in the contents of an EMP and is the crux of the guideline document. Finally, a brief description is provided of the most common generic impacts with regard to Water Resource Management projects and activities and the required generic mitigation measures.

Acronyms and abbreviations

APP:Approved Professional Person

CEIMP:Consolidated Environmental Implementation and Management Plan

DEAT:Department of Environmental Affairs and Tourism

DWAF:Department of water Affairs and Forestry

ECO:Environmental Controlling Officer under the employ of DWAF or employed as an outside Consultant to DWAF.

EES:Environmental Evaluation System

EIA:Environmental Impact Assessment

EIR:Environmental Impact Report

EMF:Environmental Management Framework

EMP:Environmental Management Plan

EMS:Environmental Management System

ESM & RS: Environmental Site Management and Rehabilitation Specifications

IEM: Integrated Environmental Management

NEMA:National Environmental Management Act (Act No 107 of 1998)

RE:The Resident Engineer under the employ of DWAF.

SEA:Strategic Environmental Assessment

SES:Directorate: Social and Ecological Services

Glossary

To assist with the understanding of this guideline, commonly used terms relevant to Environmental Management Plans and to DWAF projects are described.

Approved Professional Person

…. Also referred to as the project manager in this document.

Auditing

A systematic, documented, periodic and objective evaluation of how well the environmental management plan is performing with the aim of helping to safeguard the environment by: facilitating management control of which would include meeting regulatory requirements.

Authority

National, regional or local authority, that has a decision-making role or interest in the development.

Compensation

Trade-offs between different parties affected by the proposed development to the mutual satisfaction of all concerned parties.

Contractor

Individual and/or company responsible for the construction activities, the related activities and the implementation of the environmental management plan. In the case where DWAF is the Contractor, the Resident Engineer will be addressed as the Contractor. Otherwise, the Contractor is a private contractor qualified to Tender for DWAF projects.

Contractors representative

Person on the site representing the Contractor who is knowledgeable in environmental issues and is responsible for the implementation of the findings of the environmental plan.

Corrective (or remedial) Action

Reactive response required to address an environmental problem that is in conflict with the requirements of the EMP. The need for corrective action may be determined through monitoring, audits or management review.

Cumulative impact

An action that in itself is not significant but is significant when added to the impact of other activities in the area.

Project manager

Department of Water Affairs and Forestry representative charged with coordinating and managing the various stages of a project.

Environment

According to NEMA, the environment is the surroundings within which humans exist, being made up of:

• the land, water and atmosphere of the earth;
• micro-organisms, plant and animal life;
• any plant or combination of i) and ii) and the interrelationships among and between them; and
• the physical, chemical, aesthetic and cultural properties and conditions of the above that influence human health and well-being.

However, for the purposes of this document the environment includes both the bio-physical as well as the social and economic aspects of the area.

Environmental Management Plan Audit (EMP Audit)

A systematic, documented and objective evaluation of the environmental performance of a project by obtaining and analysing evidence to determine whether the implementation of the EMP conforms with its requirements (Swaziland Environmental Authority, 1999).

Environmental Impact

Change in an environment resulting from the effect of an activity on the environment, whether positive or negative. Impacts may be the direct consequence of an individual’s or organisation’s activities or may be indirectly caused by them (DEAT, 1998).

Environmental Impact Assessment (EIA)

The process of examining the environmental effect of development (DEAT, 1998). It is the process of assessing and incorporating potentially significant environmental impacts into the planning, design, approval and implementation of a project.

Environmental Management System(EMS)

That part of the overall management system that includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, maintaining and reviewing an environmental policy.

Environmental Objective

Overall environmental goal as stated in the EMP.

Environmental Policy

Statement of intent and principles in relation to overall environmental performance, providing a framework for the setting of objectives and targets.

Environmental Risk

The probability of a prescribed undesirable effect. Risks result from the existence of a hazard and uncertainty about its expression (Suter, 1993).

Environmental Target

Detailed requirement against which performance may be assessed, quantified where practicable, arising from an environmental objective and that needs to be met in order to achieve the associated objective. A target against which performance can be assessed.

Interested and Affected Party (I&AP)

Individuals or groups concerned with, or affected by, an activity and its consequences. These include the authorities, local communities, investors, work force, customers and consumers, environmental interest groups and the general public (DEAT, 1998).

Mitigation

Measures designed to avoid, reduce or remedy adverse impacts (DEAT, 1998).

Monitoring

The repetitive and continued observation, measurement and evaluation of environmental criteria to follow changes over a period of time and to assess the efficiency of control measures (DEAT, 1998).

Preventative Action

A predetermined action to address potential problems before they develop into situations which would be contrary to the requirements of the EMP. Preventative action is most often determined from the results of monitoring and audits during management review.

Project Appraisal

The collection and evaluation of detailed information concerning a proposed project, usually to assess risk associated with it.

Pollution

The residue of human activity which adversely affects the next user or environmental resource.

Significant impact

An impact that has crossed the threshold of significance.

Site specific investigation

An assessment or evaluation of the impact of the proposed development on the immediate environment.

Acknowledgements

These guidelines were produced with input from a number of Department of Water Affairs and Forestry staff members, both within the national office and provincial offices. Representatives from the Department of Environmental Affairs and Tourism also provided comments on the document. All those who participated in the mini-workshops and the stakeholder workshop or provided comment on draft versions of the guidelines are thanked for their contribution.

Table of Contents

Executive Summary

Acronyms and abbreviations

Glossary

Acknowledgements

Table of Contents

Table 4.1:Generic biophysical impacts and associated generic mitigation measures.

Table 4.2:Generic socio-economic impacts and associated generic mitigation measures.

1.Introduction

1.1Background to Integrated Environmental Management in DWAF

1.2Background to the development of the guideline document

1.3What is an Environmental Management Plan?

1.4The role of Environmental Management Plans within Integrated Environmental Management and where these link into the Environmental Management Framework

1.5Environmental Management Plans and the South African environmental legislation

1.5.1Legislation requiring the development of Departmental Consolidated Environmental Implementation and Management Plans

1.5.2Legislation requiring the development of project Environmental Management Plans

1.5.3NEMA principles to guide the development of Environmental Management Plans.

1.5.4Activities that Require Environmental Assessment by law

1.6Terms of Reference for the development of these EMP guidelines

2.Users guide

2.1Why standardised guidelines are required by DWAF

2.2Who should use this guideline document

2.3Environmental Management Plan guideline structure and contents

2.4How to use this guideline document

3.Generic guidelines

3.1Who should develop the EMP

3.2Key steps in developing an Environmental Management Plan

3.2.1Review of available information

3.2.2.Determine the sensitivity of the project

3.2.3Assess impacts and mitigation measures

3.2.4Develop the contents of the Environmental Management Plan

3.3What an Environmental Management Plan should include

3.3.1Summary of the activity/project background information

3.3.2Summary of the negative impacts to be mitigated

3.3.3Description of the mitigation measures

3.3.4Performance specifications

3.3.5Summary of the positive impacts

3.3.6Description of the actions required to enhance the positive impacts

3.3.7Community upliftment measures

3.3.8Cost estimates of mitigation measures

3.3.9Description of the monitoring programme

3.3.10Institutional arrangements: roles and responsibilities

3.3.11Training and capacity building requirements

3.3.12Public participation process to be followed

3.3.13Implementation schedule

3.3.14Environmental awareness process to be followed

3.3.15Documentation, record keeping and reporting procedures

3.4Auditing the implementation of an Environmental Management Plan

3.5Translation of EMP requirements into tender documents for sub-consultants

3.6Conditions under which the Environmental Management Plan should be revised

3.7Consideration of departmental documentation during the development and implementation of an Environmental Management Plan

4.Generic impacts and the associated generic mitigation measures for DWAF Water Resource Management projects

4.1Introduction

5.References

Table 3.1:An example of an audit procedure.

Table 4.1:Generic biophysical impacts and associated generic mitigation measures.

Table 4.2:Generic socio-economic impacts and associated generic mitigation measures.

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Draft guidelines for standardised EMP for DWAF projects (May 2002)

1.Introduction

1.1Background to Integrated Environmental Management in DWAF

In 1989 the Department of Water Affairs and Forestry (DWAF) formulated the departmental procedures for applying the IEM process. Since then DWAF has endeavoured to apply elements of Integrated Environmental Management (IEM) to the Department’s development projects. These procedures were amended to ensure compliance with the National IEM Guideline Series of 1992.

Recent South African environmental legislative developments (refer to Chapter 3 of the Environmental Management Framework (DWAF,2002a)) have necessitated the updating and alignment of DWAF’s 1995 IEM procedures with international trends and the current national environmental assessment and management requirements.

The need for integrated and overarching Departmental IEM procedures is strengthened by the overlapping environmental considerations of several Departmental policies, guidelines and regulations.

DWAF has proactively addressed these needs by initiating a five-phase project entitled “Revision of the Integrated Environmental Management and Development of an Environmental Management Framework within DWAF”. The first phase of this project includes developing these guidelines for standardised EMPs for use by the Department’s Water Resource Management Branch. The remaining phases will focus on implementation, application and capacity building.

In addition to the fact that not all DWAF projects have, or implement, an EMP, there is currently no standard format for EMPs. However, a generic EMP has recently been developed for DWAF Northern Province Regional Office (DWAF 2001). This document describes how generally occurring negative environmental impacts will be managed, rehabilitated and monitored and positive impacts maximised.

1.2Background to the development of the guideline document

This guideline document has been developed as part of DWAF’s initiative to ensure that IEM principles are implemented within the Department’s functions, in order to ensure compliance with environmental legislation and to promote sustainable environmental practice.

DWAF: Water Resource Management propose to standardise the EMPs that will be required by the new IEM Regulations. The EMPs will be produced by DWAF project managers in certain cases (in-house projects), or the contractors and their environmental consultants in other cases. Guidelines on what DWAF require in the EMPs will enable the efficient production of these EMPs. By standardising the EMPs, review and information finding within the plans will be made easier and the efficient monitoring of EMP implementation will be facilitated.

1.3What is an Environmental Management Plan?

Environmental Management Plans (EMPs) are important tools that bridge the gap between the completion of the Environmental Impact Assessment (EIA) and the implementation of the project, particularly with regard to implementing the mitigation measures recommended in the Environmental Impact Report (EIR) and then monitoring, auditing and taking corrective actions during their implementation. An EMP is typically drawn up after an EIA or SEA and is implemented during the construction phase and in some cases, such as in the mining industry, throughout the project lifecycle up to and including decommissioning. An EMP allocates responsibility, resources and deadlines to each of the actions. An EMP must detail actions to ensure compliance with regulatory bodies and that environmental performance is verified through information on impacts as they occur.

EMP implementation is a cyclical process that converts mitigation measures into actions and through cyclical monitoring, auditing, review and corrective action, ensures conformance with stated EMP aims and objectives.

An EMP must respond to unforeseen events and changes in project implementation that were not considered in the EIA. Through monitoring and auditing, feedback for continual improvement in environmental performance must be provided and corrective action taken to ensure that the EMP remains effective.

The objectives of an EMP should include (Hill, 2000):

• ensuring compliance with regulatory authority stipulations which may be local, national and/or international;
• ensuring that there is sufficient allocation of resources so that the scale of EIA follow-up activities is consistent with the significance of project impacts;
• verifying environmental performance through information on impacts as they occur;
• responding to changes in project implementation not considered in the EIA;
• responding to unforeseen events; and
• providing feedback for continual improvement in environmental performance.

1.4The role of Environmental Management Plans within Integrated Environmental Management and where these link into the Environmental Management Framework

Environmental management, in terms of the current IEM guidelines, EIA regulations and environmental legislation, generally operates in the following manner and sequence:

1)The EIA, a regulatory requirement for specified activities, takes place during the project planning and design phases and strives to identify potential project impacts for which appropriate impact mitigation measures are devised.

2)The EMP, although not a requirement enforced by DEAT, may be requested by the authorities as a condition of the Record of Decision, in support of the EIA and is commonly carried out during the project construction phase. The EMP may sometimes continue into the operational phase depending on the nature of the project. The EMP strives to convert the mitigation measures into actions for implementation and in this regard deals with responsibilities, resources and scheduling.

3)The Environmental Management System (EMS) is a management system that is generally organization-specific rather than project-specific and is implemented during the operational phase, providing a framework for organizational structures, reporting, internal and external communication, monitoring and review, and training.

These three tools (EIA, EMP and EMS) essentially compliment each other in a variety of ways and overlap with regards to many of their principles, objectives and requirements. The associations between the three tools may be described as the EIA predicting potential impacts, the EMP managing the impacts and the EMS providing an overarching framework for managing the EIA and EMP and which requires the EIA and EMP for its implementation.

The critical link in terms of developing an EMP is the information that precedes it, or feeds into it. The key source of this information is the Environmental Assessment (EA), which has to date usually been the EIA, and it is therefore essential that the EA is undertaken to a sufficiently detailed level, ensuring that relevant, accurate and appropriate information on impacts and mitigation is fed through to the EMP. It is important to note that an EA may not necessarily have been completed for a project or activity requiring an EMP. This does not alter the importance of the need for information essential to the EMP.