EIA and EMS integration: not wasting the opportunity

Abstract

Environmental tools such as environmental impact assessment (EIA) and environmental management systems (EMS) can be applied to ensure that major projects are constructed and operated using an approach that enables effective environmental protection. Previous research has shown that these tools are frequently applied in isolation at different stages of the project life cycle. The extent of EIA/EMS integration amongst nine of the biggest UK waste management companies was investigated through semi-structured interviews with environmental staff and thematic analysis of their responses. The research found that partial integration of EIA and EMS is widespread. Companies recognised a range of potential benefits to more closely integrating their processes such as system efficiencies, data availability and recognition from the regulator. However, significant barriers to further integration were identified in the form of cost, company structure and the size of the organisation. In a context where the regulation of the waste industry is increasingly aligned towards a risk-based approach, there is a new opportunity to use EIA outputs in an enhanced EMS. More generally, companies should seek to maintain continuity of personnel across the project life cycle and structure their environmental functions so that EIA and EMS staff can work more closely. This would help ensure that the greatest benefit is derived from both tools.

Keywords::

• EIA
• EIA follow-up
• EMS
• integration
• waste
• UK

Introduction

It is widely acknowledged that environmental impact assessment (EIA) and environmental management systems (EMS) are the most commonly used environmental management frameworks for different stages of the project life cycle. Both have had varying degrees of success in bringing about effective environmental protection as they are ‘complementary processes, which have a common characteristic that is related to environmental protection’ (Obradovic 2011). To date, however, there has been little research on how these tools are used in tandem (Lundberg 2011). It has been proposed that linking the two enables a more comprehensive approach to environmental management (van der Vorst et al. 1999; Ridgway 2005).

Whilst ‘the processes of EIA and EMS might be perceived as two sides of the same coin’ (Eccleston & Smythe 2002), each has its own functions and differences. Although complementary, these differing functions are why these ‘environmental planning and management tools’ (Sánchez & Hacking 2002) are often not more actively linked by companies. As de Ridder et al. (2007) state ‘there is no “one size fits all” with respect to [the] tools, nor can one tool do the job’ which is why this article posits whether the weaknesses in the EIA process can be addressed by the EMS process and vice versa. Commentators have been discussing for almost two decades the role of EIA follow-up, a potential ‘missing link’ from EIA. Could EMS fulfil this role if properly linked to the EIA process which precedes it? ‘Follow up’ is used to describe EIA activities including ‘monitoring, auditing, ex-post evaluation, post-decision analysis and post-decision management’ (Morrison-Saunders & Arts 2004). Whilst in most countries like the UK, EIA follow-up is not mandatory and thus has had questionable impact (Tinker et al. 2005), Arts (1998) explored the role that follow-up can play, particularly in the context of the Netherlands where it is compulsory. EIA follow-up has been further examined by numerous researchers since (see Arts et al. 2001; Morrison-Saunders et al. 2001; Marshall 2002, 2005; Sánchez & Hacking 2002; Morrison-Saunders et al. 2003; Gallardo & Sánchez 2004; Marshall et al. 2005; Morrison-Saunders & Arts 2005; Lee 2006; Jay et al. 2007; Morrison-Saunders et al. 2007; Jha-Thakur et al. 2009; Lundberg 2011).

Research on the interlinking of EIA and EMS on a case study basis has occurred over a number of industries, such as the Finnish paper industry (Kuisma et al. 2001), for pipeline projects (Lien & Colosimo 2008) and industrial estate developments (Slinn et al. 2007). There are also case studies which examine the linking of the tools within a single organisation, including examples from the renewables (Becker 2012), oil and gas (Raissiyan & Pope 2012) and waste (Palframan 2012) sectors. However, to date, there has been no research examining practices within multiple companies across the UK waste management sector. This paper therefore investigates the interaction of EIA and EMS within nine UK waste management companies, assessing the potential benefits that could be realised and the barriers that are currently preventing the tools from being more closely linked. We examine the potential to introduce improvements in light of a changing regulatory regime and highlight the potential for improvements to be applied more widely within different contexts.

The need for effective environmental management tools

Despite the current economic climate, investment in UK infrastructure currently averages £45 billion a year (HM Treasury 2013). This raises significant environmental issues, not least because ‘infrastructure projects tend to have more widespread impacts than other projects’ (Christensen et al. 2005). Some of these issues are addressed during the planning and permitting processes which consider, for example, the suitability of the site and any alternatives to it, noise, traffic, statutory nuisances, visual intrusion, cultural heritage and public concern (Defra 2007).

Because the use of environmental resources and ecosystem services is intrinsically linked to economic development, humans continually deplete the very resources required to sustain themselves. With global population growing by 80 million each year and estimated to rise to 9 billion by 2043 (United Nations 2011), innovative methods of providing fuel and electricity and managing the amount of waste that is produced by the growing population is vital as is the need for effective environmental tools.

The waste management industry

Within a global waste management industry context, many countries lack sophisticated methods of waste management, for example even wealthy countries (in terms of GDP per capita) such as Qatar currently lack mature waste disposal and recycling infrastructure (Al-Maaded et al. 2012). Disposal usually means ‘burn or bury’ either through landfill or in some cases, open or unregulated burning (Bournay et al. 2006). According to The World Bank Group (2011), 30–60% of waste from some developing countries remains uncollected, leading to unregulated waste management practices.

Within the UK waste management sector, a diverse range of technologies is deployed including anaerobic digestion; combined heat & power; materials recovery facilities; mechanical, biological treatment facilities and other energy from waste plant. The sector is responsible for the safe handling and disposal of over 75 million tonnes of municipal, commercial and industrial waste each year (Environmental Services Association 2011a) and even within the current economically constrained environment is looking to invest £10–20 billion in new facilities between now and 2020 (Environmental Services Association 2011b). The effective management of these facilities is crucial; companies need to make efficient use of available environmental management tools to enable them to meet regulatory requirements.

In England and Wales, under the Environmental Permitting Regulations (EPR) (England and Wales) 2010, large waste management facilities require an environmental permit (EP) in addition to planning consent before construction can commence. The permit sets out the standards and measures that are needed to minimise risk of pollution from a site such as those relating to management systems, control of emissions, staff competence, monitoring and record keeping. The permit will have a range of conditions attached, designed to ensure compliance to UK and EU legislation and may well impose upper limits or thresholds that may be site-specific or apply to all facilities of a certain type (Environment Agency 2013c). The Environment Agency also uses a risk assessment tool, known as operational risk appraisal (OPRA) to assess sites in terms of the hazard they pose and the effectiveness of their management. OPRA places sites into a series of bands which indicate facility performance and determine the regulatory regime, for example the frequency of inspections (Environment Agency 2013b).

Integration of EIA and EMS: the current situation

An EIA is carried out prior to a development taking place and seeks to minimise significant environmental effects, while an EMS is put in place to manage ongoing impact, with ‘the weaknesses of one system tend[ing] to be offset by the strengths of the other’ (Eccleston & Smythe 2002). Both are designed to ‘answer the same questions – “What needs to be managed?” and “How should it be managed?”’ (Sánchez & Hacking 2002) but at different stages of the development process.

EIA seeks preliminarily to influence design, whereas EMS is a useful framework for the construction and operation stages. Within the environmental management toolbox (Finkbeiner et al. 1998), they can be linked to manage impacts across the development life cycle (see Figure 1).

Figure 1 Enviromental tools in the development control process. Copyright © 2006 John Wiley & Sons, Ltd. and ERP Environment. Reproduced by Permission of Slinn et al. (2007).

Slinn et al. (2007) discuss how the tools inter-relate but it is clear that currently, they are only partially linked from the point a project is initiated. Previous research has questioned whether the EMS process is merely an extension of EIA or, conversely, whether EIA is necessary if an effective EMS is in place from the outset of a planned project (Obradovic 2011). This suggests that one tool could substitute the other. However, this neglects to consider that EIA influences the eventual design of the project; could this be said of EMS?

A less radical solution to the use of EIA and EMS is that there should be a link as EIA ends and EMS begins (indicated by the two circles of the tools overlapping in Figure 1). Provided the tools are not used ‘in silos’, the EIA can provide the baseline information which can then formulate the EMS or assist in future developments of a similar nature (Department of Environmental Affairs and Tourism 2004; Glasson et al. 2005; Palframan 2010). However, it is clear that EIA's usefulness decreases as a project moves away from planning and design and into construction and operation (see Figure 2).

Figure 2 Relative usefulness of EIA and EMS by project phase.Copyright © 2005 Taylor & Francis Group. Reproduced by Permission of Ridgway (2005).

EIA and EMS, when linked together and used in a follow-up capacity provide a structure for the reliable assessment of environmental impacts and their ongoing management and mitigation, whilst also acting as an information conduit to interested parties (van der Vorst et al. 1999).

Current issues with EIA and EMS

Insufficient implementation of mitigation measures has been highlighted as a flaw of EIA (Sánchez & Hacking 2002), and research has found EIA to be successful in some respects (Tinker et al. 2005; Jay et al. 2007; Obradovic 2011; Bassi et al. 2012) but has also questioned its overall effectiveness, particularly when there is no legislation requiring follow-up (Arts 1998; Nitz & Holland 2000; Gallardo & Sánchez 2004; Slinger et al. 2005; Morrison-Saunders et al. 2007).

A further challenge is that although EIA can predict environmental impact, there is no analysis of whether what is predicted actually occurs once a facility is built. In other words, ‘from the developer's point of view, it really does not matter if predictions are inaccurate: the developer will suffer no consequences’ (Dipper et al. 1998).

Tinker et al. (2005) indicate a flaw with the EIA process in that ‘the time lapse between submission of an [Environmental Statement] and granting of planning permission may mean that the [Environmental Statement] is out of date by the time planning conditions are formulated.’ To elucidate this from a waste management perspective, by May 2013, work had yet to start on construction of an estimated 21.3 million tonnes of waste processing capacity in the UK which had already received planning consent (Eunomia Research and Consulting 2013).

Whilst the following quotation may appear to provide a conclusive overview of the success and failures of the EIA process, it disregards (to an extent) the effectiveness of planning conditions: ‘EIA as a process is not management focussed and lacks the framework elements that are common to modern management systems, namely: plan, do, check, review’ (Ridgway 1999). If this quote is taken at face value, it is fundamental to therefore look to EMS to deliver these missing elements.

A formal EMS such as one certified to the ISO 14001 standard, sets out a framework for identifying, managing and measuring the impacts of the interactions between a business and the environment, facilitating environmental improvements. EMS encompasses several of the other environmental management tools (Burström von Malmborg 2002; Annandale et al. 2004; Emilsson et al. 2004) and can have both tangible and intangible benefits that lead to better environmental performance in aspects such as reducing waste, implementing better recycling initiatives, lower emissions, greater material efficiency and so on (see Rondinelli & Vastag 2000; Ammenberg & Hjelm 2002; Melnyk et al. 2003; Ann et al. 2006; Briggs 2006; Radonjič & Tominc 2006; Walker et al. 2007; Yin & Schmeidler 2007; Darnall et al. 2008; Hanson et al. 2008; Nawrocka & Parker 2009; Puvanasvaran et al. 2010; Heras-Saizarbitoria et al. 2011).

Previous research has also noted certain ‘intangible’ environmental performance improvements that an EMS can bring about (Briggs 2006; Radonjič & Tominc 2006; Darnall et al. 2008; Puvanasvaran et al. 2010), for example, improved environmental awareness among employees (Rondinelli & Vastag 2000). EMS is said to be the engine of environmental management tools (Emilsson et al. 2004), driving management regimes and problem-solving initiatives through its systemic, cyclical process. However, EMS too has notable flaws.

Whilst studies have found that EMS can have a positive impact on environmental performance, some have raised doubts about its influence (Melnyk et al. 2003; Ann et al. 2006; Hertin et al. 2008; Heras-Saizarbitoria et al. 2011). Since an EMS is for an internal audience and not mandatory (like EIA follow-up), it lacks the public participation element of EIA (Sánchez & Hacking 2002; Obradovic 2011), which can be vital in safeguarding positive environmental consequences. Also, if stakeholder pressure is the only reason for undertaking an EMS, its benefits can be lost and its influence disputed (Ilomäki & Melanen 2001; Annandale et al. 2004). Furthermore, criticism of the EMS process has focused on its ‘emphasis on management procedures, rather than actual improvements in environmental performance’ (Brouwer & van Koppen 2008), a claim supported by Keen and Sullivan (2005) and Lundberg (2011).

Both EIA and EMS can have a positive effect on environmental outcomes, but not necessarily at the same stage of the development process. Because ‘the EIA process can provide a practical plan to prevent pollution, and EMS ensures that measures to prevent pollution are continuously performed during the operational phase’ (Obradovic 2011), it stands to reason that drawing the tools together in a more systematic process reinforces them and means the relative weaknesses of each can potentially be offset by the other's strengths.

Methodology

Interviews were conducted with representatives from UK waste companies that were identified as both undertaking EIA for capital developments and having a formal EMS (e.g. certified to ISO 14001) on their operational sites. All companies were members of the Environmental Services Association (ESA), the UK's trade association for waste and resource management companies.

Previous research has indicated that EIA and EMS tends to be the responsibility of different specialists due to their different skill sets (Ridgway 2005). This was confirmed when relevant contacts were scoped through discussions with company representatives, and so, the member of staff with the best overview of both EIA and EMS was selected for interview. In each case, the individual's primary involvement was with EMS but they interacted with staff with EIA responsibilities located elsewhere in the company (e.g. Planning/Estates department). Of 15 companies that were approached, nine supplied an individual for interview. Sample size was influenced by previous research which suggested that a maximum of 12–15 interviews was sufficient before data saturation was reached (Guest et al. 2006; Nykvist & Nilsson 2006). All interviewees had worked in the sector for at least 3 years.

Semi-structured interviews were undertaken between April and July 2012. Standard themes were explored with all participants in order to attain consistent results (see Box 1 for themes and Table 1 for a summary of results), and these were used as a starting point to stimulate further discussion. All interviews lasted between 20 and 70 min, with the majority being around 40 min. Interviews were recorded and carried out face to face where possible because this can produce greater ‘richness’ of communication (Gillham 2000) although four of the interviews were conducted by telephone at the interviewees' request.

Box 1. Standard themes explored with all participants.

What are the similarities and differences in the ways waste management companies undertake EIA and EMS?

Do companies see any benefits and/or experience any problems with the EMS or EIA processes?

Do companies integrate EIA with EMS?

What barriers exist to increased integration?

Table 1 Quantitative summary of responses.

Question	Number of respondents in parentheses
Do you have involvement with EIA?	33%Frequent (3)	56%Occasional (5)	11%None (1)
Do you have involvement with EMS?	100%Frequent (9)	0%Occasional	0%None
How is EIA carried out?	0%In house	78%Consultant (7)	22%Mix (2)
Do you operate a certified EMS and if so, is this integrated with other systems?	89%ISO 140001 for all sites (8)	78%Integrated 9001/18001/14001 (7)	22%Not integrated (2)
Is EIA/EMS currently integrated at your company?	22%Yes (2)	44%To some extent (4)	33%No (3)
Could EIA/EMS be integrated at your company in future?	56%Yes (5)	33%To some extent (3)	11%No (1)

The interviews were transcribed from the recordings as an edited verbatim transcript in order to keep the accuracy of the interview, but remove unnecessary stop words. Thematic analysis was carried out [as described by Aronson (1994)] whereby recurring themes were noted, and similarities and differences between the approaches used by different companies were compared and contrasted.

Results and discussion

A quantitative summary of the responses to interview questions is provided in Table 1. The qualitative findings from the interviews are set out in the following section by firstly explaining in more detail the ways in which the interviewees were involved with EIA and EMS. The benefits and problems they perceive with each of the tools are outlined. The degree to which companies are currently integrating the tools and the issues they experience in achieving this integration are then discussed. Finally, opportunities and barriers to further integration are explored.

Background of interviewees and companies

As discussed, all interviewees had responsibility for EMS as part of their job. In most cases, they were responsible for the system's upkeep. It was therefore necessary to establish their involvement with EIA. Only one individual (11%) interviewed had no interaction at all with EIA (though the individual's company used the tool), with three (33%) others having regular and five (56%) having occasional interaction. With regards to who carried out EIA, seven (78%) of the respondents reported using consultants to undertake their EIA, with the remaining two (22%) using a mix of in-house experts and consultants.

The employees that interacted with their own planning department or had a technical aspect to their job role in general tended to be more likely to interact with the EIA process. It was noted that with Environment Agency permits requiring assessments of environmental hazards and risks, there was a degree of overlap with EIA; in fact, one interviewee who identified EIAs as ‘pretty theoretical’ also claimed that ‘environmental risk is running on the job’, thereby indicating that environmental risks were felt more likely to be mitigated against ‘on the ground’ than through the more ‘hypothetical’ EIA process. Most individuals (67%) regularly interacted with environmental risk assessments (ERAs), either through a simple identification of source, pathway and receptors or through the Due Diligence process of a new or potential acquisition. This process is significant as there have been a considerable number of mergers and acquisitions within the waste management industry over the last 6 years (Hall 2007, 2010; Grant Thornton UK LLP 2012).

Whilst most companies (89%) had ISO 14001 in place for all sites, one company had ISO 14001 for the majority of sites, but also had an eco-management and audit scheme (EMAS) at others as part of a contractual agreement because ‘EMAS is over and above 14001.’ Whilst one of the flaws indicated with an EMS was that there was no public engagement, within the EMAS, this external communication is included, thereby solving this problem (see van der Vorst et al. 1999). The reasons for seeking ISO 14001 certification varied but interviewees said they originally put the system in place due to customer demand and also to an extent for corporate image – the public want to see companies ‘doing the right thing’. Seven of the nine companies (78%) also operated an integrated management system for quality management (certified to ISO 9001), health and safety management (OHSAS 18001) and environmental management (ISO 14001).

Benefits and flaws of the EIA process

Several interviewees (22%) stated that as a matter of good practice, their waste management companies will undertake an EIA for a project even if it does not fall under the EIA Regulations. This suggests the waste industry is to an extent self-regulatory, proactively seeking to address negative environmental impacts.

A number of concerns were raised relating to the individuals carrying out EIA. Regarding a lack of expertise, such as having in-house ecologists within individual companies, it was noted by one interviewee that the EIA process was beneficial as a ‘learning curve … the more [EIAs] you do, the better you get at them, and the more information you can share for other documents’. The individual also mentioned that after undertaking EIAs for similar projects, they could expect to see certain elements recurring within the reports written by their external consultants, such as in the environmental statement. The process also highlighted what could be ‘scoped out and what could be left in’.

Concerns were raised about the use of EIA consultants. Whilst competitive tendering does have some advantages in terms of cost savings, it was noted by one individual that ‘sometimes it's better to pay slightly more [of] a premium to get the quality of the product.’ In support of this statement, another interviewee indicated that the biggest issue they had with using consultancies was the generic way in which EIA reports were undertaken. In the example, they cited that a consultancy ‘once filled an Environmental Impact Assessment in for a landfill, and the consultants had cut and pasted a whole section in for a transfer station with an anaerobic digestion plant built on the other end. It was slightly embarrassing.’ It is unsurprising, therefore, that the environmental professionals interviewed tended to use the same consultants for undertaking EIAs. Whilst however this addresses a flaw identified with EIA that often the ‘environmental knowledge and learning’ (Lundberg 2011) gained from a project's development to its construction is not transferred between various stakeholders, it fails to highlight the role that EIA follow-on or an EMS can play in helping to keep environmental knowledge and learning ‘live’ within the company.

A number of the interviewees (33%) felt that EIAs ‘tend just to be done at the start and then they're forgotten about’ and as mentioned previously, that EIA is ‘pretty theoretical’ and that it represents a ‘snapshot in time… they don't reflect what's actually going to happen over the next couple of years’. Previous studies have identified the frequent time lapses between the EIA and development completion as a potential limit to EIA effectiveness (Tinker et al. 2005). Again this concern does not recognise the role that EMS (and indeed EIA follow-on) can play in ensuring EIA outputs are integrated with the EMS.

Benefits and shortcomings of EMS

Numerous benefits were identified by the individuals of having an EMS, with controlling risks, lowering insurance premiums and reputational benefits being the most frequently mentioned [see Heras-Saizarbitoria et al. (2011) for a list of studies indicating key benefits]. Regarding reputation, one interviewee said employees ‘recognise it's not tree hugging any more…they recognise that there are cost benefits to managing environments, reputation-wise they know that [we have] a good environmental reputation … and that it improves the relationship with neighbours’. Much like in the EIA consultation process, this leads to an additional point regarding attaining stakeholder ‘buy-in’ and ensuring they are engaged at every step in the EMS chain. This aspect was mentioned by several interviewees (44%), who said that achieving full employee engagement with implemented procedures was always a challenge. As one interviewee said ‘there's no point in having a management system if you're just going to tick a box; it's a waste of time, effort, energy and cost;’ so, it really is a fundamental aspect to embed the EMS in the company's culture as having objectives without ever being able to achieve them is meaningless.

One of the recurring points regarding the interviewees' experience of EMS was the sheer scale of environmental aspects that needed to be captured. As one interviewee said ‘you're always identifying things that you feel perhaps need to be captured; at the same time you're always trying to rationalise it to keep it as lean as possible so that it is as user-friendly as possible.’ This rationalisation of documentation was mentioned by 78% of the respondents, with certain companies trying to implement procedures at a divisional rather than local level so that all procedures are applicable across all facets of the company. In fact, one interviewee said the main problem with EMS ‘is actually the number of documents you have in the system’. Puvanasvaran et al. (2010, p. 4713) classify this as ‘attendant bureaucracy’.

One suggested way to alleviate some of the voluminous documentation was to move from a procedurally-led operation to a competence-led operation or in the interviewee's words, ‘have an ethic that is systems and procedures driven…one that is very much based on the competence of individuals that work within the system’. Of course, what better ethic would there be to have a system in place which incorporated all the positive aspects of EIA and EMS?

Integration of EIA and EMS

Having noted that EIA and EMS are used by each of the companies, respondents stated that EIA and EMS were already integrated (22%) or were integrated to some extent (44%), with only three (33%) stating that they were not integrated.

One of the two companies who said they were already integrated said they use the Environmental Statement (EIA Report) as the basis for risk and from there aim to negate detrimental impacts by feeding this information into a working plan for that particular site. The other company who claimed EIA and EMS were already integrated said ‘we don't distinguish between the two [tools]’. It is promising therefore that of the nine companies interviewed, two (22%) reported having already integrated EIA and EMS across their organisation.

As mentioned previously, under the EPR (England and Wales) 2010, an EP is needed to operate most waste management facilities. Because the EP is the ‘overarching mechanism for regulating [waste management facilities]’ (WRAP 2012), it was noted by interviewees whose companies do not directly link the tools that this is where they see the links between EIA and EMS being most apparent. One interviewee said ‘I think there are many linkages that occur as a result of the way that the planning and permitting process works’ and another mentioned ‘you just take your planning, look at your conditions and implement appropriate controls’ – so that through the planning and permit conditions or in other words, the regulatory regime, companies are linking the two environmental tools to an extent. Previous research has noted the use of environmental management plans within a waste company to ensure that EIA commitments and EP conditions are complied with (Palframan 2012). The importance of knowledge transfer between the two tools for an external audience (through permitting and the involvement of the regulator) was noted by Becker (2012).

It was noted, however, by the individuals who claimed that EIA and EMS were linked to an extent (44%) that this happened almost by accident rather than an intentional exercise – ‘certainly we don't as a particular process, think about or assess whether the impact actually as assessed is consistent with the original [EIA].’ Another interviewee who said that EIA and EMS were partially linked stated ‘lessons learned from the Impact Assessment are usually fed … forward to new projects when they're being commissioned.’ This links to the development control process shown in Figure 1, indicating that within a waste management context, EIA and EMS overlap to a much greater extent than expected. In fact, Figure 1 could be revised to reflect this by adding in a new link from the site being fully operational back to the developer initiating the project. This would show the additional step of a more proactive approach to linking the tools as the information uncovered by the EIA and EMS process is incorporated into new projects as suggested above. Though this represents a simpler approach than the alternating-sequence conceptual framework put forward by Perdicoulis and Durning (2007), it would still result in a more harmonious use of the tools.

Conversely, one company claimed that the tools were not linked as they were seen as ‘two quite separate and distinct functions’. This was supported by another assertion from a different interviewee who stated that they would not ‘sit with the EIA next to me and … build the EMS from that’. It is evident that there exists a considerable variation in the way in which waste management companies utilise the tools.

Interviewees were also asked if it would be possible to integrate the tools if they were not already, and if they were, whether they could be integrated further. Only one respondent said that it would not be possible, with the remainder (89%) indicating the tools could be integrated further.

One interviewee said that increased integration could happen when a facility is in the final stages of commission after undertaking an ERA. It would then be possible to re-visit the EIA as ‘some projects will have changed quite a lot since the original Environmental Impact Assessment was undertaken.’ Any new hazards identified or those that were identified but not satisfactorily eliminated could then be included in an enhanced EMS. It was generally agreed by interviewees that EIA and EMS could be linked by design rather than by default. As Varnäs et al. (2009) state, ‘instead of viewing the findings of the EIA as inputs to the EMS, the EIA and the EMS can be integrated to make the [ES and EMS] more dynamic.’

Linked to the permitting aspects outlined above, one interviewee raised the possibility that linking the tools could demonstrate corporate competence. Several of the waste management companies interviewed are currently involved in the EPR Assurance Scheme pilot project using ‘Annual Statements of Compliance’ to demonstrate how they comply with permit conditions. The pilot is being run in conjunction with the Environment Agency with the idea being that ‘light touch regulation’ will be applied to the companies that demonstrate stronger control of their risks. If successful, the EPR Assurance Scheme will be fully implemented in April 2015 (Environment Agency 2013a). Part of the pilot scheme involves utilising an enhanced EMS, or ‘EMS+’, which uses the existing certified EMS (ISO 14001) with an extension to ensure that the operator has all the systems in place that would enable compliance with all the conditions in their Permit as well as the systems to ensure they operate the Permitted process compliantly. Effectively, ‘you use your independent certification body and a demonstration of your compliance via this EMS+ tool to satisfy the Agency that you have everything in place.’ This is discussed further in the next section.

Benefits of integration

After discussing with the interviewees their own experiences of the EIA and EMS process and asking whether there were any positives to linking the two, nearly all individuals (89%) were able to recommend at least one reason to do so (see Figure 3).

Figure 3 Most frequently cited reasons to integrate tools (results indicate number of companies giving the response).

The most commonly mentioned benefit was that a ‘jointless system’ would mean that information was not lost through the different environmental processes, making the approach to environmental protection more efficient. The permit application, the ES and the EMS would all sit side-by-side; so, this benefit complements others (e.g. ‘help regulators make better decisions’ and ‘leads to better communication’). Having a ‘jointless system’ would mean having key information in one place; this in turn could promote improved communication between stakeholders and internal departments. It could also enable streamlining of staff through better deployment, which could save money, and it would provide real working data on environmental risks throughout the whole project life cycle. As one individual noted, ‘I actually think integrating them together, providing you've done the integration right to start, you stand less chance of losing the good bits.’ Because EIA follow-up is often neglected or at least lacks rigour in many jurisdictions (Morrison-Saunders & Arts 2005), this integration would provide a more holistic approach, ensuring the tools are not used in isolation.

It was also noted that integrating the tools could help regulators make better decisions when issuing a permit to a company for a particular site. For example, an EP may have certain requirements, say for emissions to air, and the EIA may identify mitigation measures to reduce emissions to air, but often, the two are not actually linked together. This would ‘remove the potential level of contradictory conditions’ which also poses a current barrier.

The final set of benefits identified revolved around sending a powerful message and providing examples of best practice, thus speeding up implementation at future sites. These benefits would also help demonstrate compliance, as an interviewee said ‘it's quite a powerful message, to be able to say well actually this is what we designed, this is what we predicted and this is what happened.’ For a waste management company to be able to tell the regulator ‘this is exactly how we mitigate impacts’ would indeed be a powerful message and could help raise the OPRA band for the facility (Environment Agency 2013b). This is an important point that a combination of the tools used in an ‘EIA follow-up’ capacity can capture mitigation measures and ensure monitoring and compliance throughout the project life cycle.

Barriers to integration

Far fewer barriers to integrating the tools were mentioned, although these were by no means insignificant (Figure 4).

Figure 4 Most frequently cited barriers to integration (indicating the number of companies responding).

Unsurprisingly, cost (both time and money) was the most frequently mentioned barrier. As discussed, the EIA process requires a large number of experts assessing a wide range of issues; if the tools were linked, the respondents believed such experts would also be needed to re-assess the EIA and whether the impacts for the built development were as originally predicted. Further to this, companies bemoaned the cost of undertaking an EIA with the current number of consultants needed; to increase the cost would simply be unfeasible in their view. As one interviewee said

if you think about the fact that Environmental Assessments involve pulling in a whole range of experts to assess various situations, you'd need those experts essentially to come back and re-assess, or a separate set of experts. So there is quite a cost issue regarding someone to look at what is a significant number of areas.

Whilst the UK waste management industry is expected to grow by 3.1% in 2013–2014 and was valued at over £12 billion in 2010–2011 (HC Deb 2012–2013), it is expected that companies may seek to avoid further costs in addition to those incurred in undertaking an EIA given the current economic climate. Building on research undertaken by Arts and Nooteboom (1999) and Rondinelli and Vastag (2000), Marshall et al. (2005) noted that the costs associated with follow-up could be managed by tailoring the approach according to the needs of each project. Tinker et al. (2005) proposed that further research was still needed into cost-effective options for improving practice.

A second major issue is the fact that different departments lead on the two tools and for the EIA to feed into the EMS would require a departmental reshuffle for many companies. This links into the third point about the size of the organisation – as one individual said ‘we're too large an organisation … we also have a separate independent Planning department …. And they sit outside of the Environment department, so they are not linked to us at all.’ The challenges of staff being involved with each tool but working within different parts of an organisation were also highlighted by Fuller et al. (2012) with respect to flood risk management.

Whilst it has been said that ‘the links between EIA and EMS in most organisations are still weak’ (Ridgway 2005), this research indicated that there do exist considerable links between the processes in the waste management industry. More telling is the fact that only one of the interviewees claimed that the tools could not be integrated, which suggests that environmental practitioners are open to the possibility of integration.

Encouragingly, there were more positive reasons for increasing integration than negatives, although conversely, the barriers to integration were perhaps more significant. This is likely to be the same for other industries, but the deterrents may be greater for industries in countries which lack a strong environmental protection framework.

Moving practice forward

The findings suggest that in the UK waste management industry, links between EIA and EMS occur by default, principally through the permitting process, rather than by design. In other highly-regulated industries, a similar scenario may be expected. In this situation, further coincidental integration is unlikely; therefore, it is necessary to escalate efforts to draw the tools together intentionally.

One of the ways the waste management industry could do this is through the Responsibility Deal signed between Defra (the UK environment ministry) and the ESA (the waste trade association) on behalf of the waste management industry (Defra 2011). The deal recommended piloting Annual Compliance Statements (ACS) with an independent audit to confirm compliance. This pilot now sits within the EPR Assurance Scheme with the additional use of an ‘EMS+’ for top rated OPRA A or B banded facilities. EMS+ aims to upgrade the existing EMS process with the use of an additional permit compliance checking tool. If results from the EIA process were fed into the EMS+ stage, it would ensure greater integration between the tools. Because the EPR Assurance Scheme can be specifically tailored to each industry sector, it means that even if a responsibility deal is not in place, the process can be undertaken by other regulated industries.

Other countries with a mature environmental protection framework could consider piloting similar schemes with industries that have potentially environmentally damaging activities. Whilst at the moment, the EMS+ is a pilot, it does mean that these considerations from the EIA could be built into the EPR Assurance Scheme so that when the scheme is ‘rolled out’ in 2015, this integration is incorporated. Although the present thinking with the scheme appears to be based on having the ACS and the EMS+ sitting ‘side-by-side’, a more efficient option may be to use the EMS+ as the main tool and ensure the other aspects feed in so that the process is more wholly integrated and thus augmented (Figure 5).

Figure 5 An augmented EMS+ system.

Having the EMS+ sit at the centre of the EPR Assurance Scheme would mean that information from a company's internal ERA, together with their externally verified EMS (ISO 14001), ACS, independent audit and information from the EIA (e.g. regarding impacts) would collectively provide a more comprehensive environmental protection system; we refer to this as an augmented EMS+.

For simplicity, within Figure 5, certain permit and planning conditions that feed into the ACS, EIA and EMS have not been included as a separate item in the process, but they could be in practice. In fact, the use of the augmented EMS+ tool may bring interesting developments to the permit process as the augmented system goes beyond the requirements of each of its constituent parts. If a developer were to state their intentions of operating an augmented EMS+ system from the outset at project initialisation, does a ‘normal’ EMS (such as one certified to ISO 140001) then have less influence? Does the augmented EMS+ add unnecessary complexity or as Sheate (2009) posits ‘Do we, then, need new tools or can we make existing tools work better together?’ Once the results of the EPR Assurance Scheme pilot are released, the success of the existing tool can be judged and an assessment of whether further refinement of the tool (as the authors of this article suggest) can be made.

For countries which do not operate an equivalent scheme, further consideration should be given to how non-legislative tools can be utilised to link EIA and EMS and thus promote environmental protection more satisfactorily. From a follow-on point of view, Ramos et al. (2004) state ‘An important reason for the less than satisfactory performance of environmental monitoring programs may be that they … have not been designed to contribute to a synthesis of information or to evaluate project impacts, or analyze the complex cross linkages.’

A key challenge identified was the lack of transfer of information from the EIA process to the operational EMS due to a lack of continuity in personnel. This issue was also recognised in the oil and gas sector by Raissiyan and Pope (2012) who suggested that some representatives of the EIA team should remain engaged in the project until the EMS is fully operational. Whilst this solution could be implemented by bringing all aspects of EIA in house, in practice, this is not usually feasible due to the wide range of specialist knowledge required. As Petts (1999) states ‘the quality of any particular EIA relies as much upon the quality of the individuals who undertake it as on the adherence to any particular procedure or application.’ Therefore, companies could consider building a good quality relationship with a single consultancy. Alternatively, they could select consultants whose EIA work has been assessed against a recognised standard (COWI 2009), such as the UK's IEMA EIA Quality Mark (IEMA 2011). A further recommendation is that whilst it may not be possible to reorganise company set-ups and structures, ensuring closer working links between the planning/estates department (usually responsible for EIA) and the individuals responsible for EMS would ensure better communication between stakeholders throughout the life cycle of the project, from planning permission to operation to decommissioning. Building closer links and increasing knowledge-sharing between departments would enable a more joined-up approach to environmental protection. Of course, if companies could be structured so that departments overseeing EIA and EMS could work together more closely, then this may bring even greater levels of communication and knowledge sharing benefits, thereby ensuring that EIA follow-up is a fully integral and integrated process for all developments.

Incorporating these points would truly enable companies to send a powerful message that they take a proactive, joined up approach to environmental protection, which would also reduce duplication of effort and potentially deliver financial savings. This could prove attractive to companies operating in the current constrained economic climate. Furthermore, the regulator would benefit from spending less time auditing high-performing facilities operating an augmented EMS+ system, freeing up resources for other activities. However, with reference to England and Wales, this system should be restricted to companies in the high performing OPRA A or B band which means a significant number of facilities would not be eligible unless they improved their performance.

Conclusion

From the results identified, it is evident that waste management companies are to some extent already linking EIA and EMS, mostly through the permitting process, and that within a waste management context, the tools are beginning to ‘fit together like a hand in a glove’ (Department of Environmental Affairs and Tourism 2004). As existing research demonstrates that EIA and EMS are not widely linked across other sectors, it is commendable that even the current levels of integration are occurring within the waste management industry.

The key motivators mentioned for integrating the tools were mostly procedural as this could lead to better ‘jointless’ systems and reduce duplication of effort, whilst enhancing communication between the departments responsible for each of the tools and external stakeholders such as the public. Some of the other motivators were perception-based, such as sending a powerful message to stakeholders and being seen as ‘best practice’ within industry, which could also enhance the regulator's opinion of the company.

The key barriers identified were cost (both time and money) and the inflexibility of current company structures as different departments are responsible for each of the tools, a situation which does not permit the tools to be more closely integrated. Ultimately, it was felt that these barriers were likely to be a significant deterrent to companies even where integrating EIA and EMS may be both appropriate and advantageous.

It is the interests of the company, regulator and the public that the environmental impacts of large infrastructure projects are managed rigorously, but in a systematic and efficient manner. As both companies and regulators seek to protect the environment while avoiding duplication of effort, closer integration of EIA and EMS can be seen as an essential step in the right direction.

Acknowledgements

The authors would like to thank the Environmental Services Association and the waste management professionals who participated in this research.