Integrating Environmental Impact Assessment with Environmental Management Systems

In January 1970,

when the National

Environmental Pol-

icy Act (NEPA) be-

came law in the

United States, it was

intended as a federal

response to increas-

ingly serious domes-

tic problems of environmental pollution and nat-

ural resource degradation. At that time, few if any

imagined that it would become the cornerstone

of a new applied science of environmental impact

assessment (EIA), and that its basic elements

would, over the next 30 years, be replicated in the

laws and planning requirements of approxi-

mately 100 countries around the world.

Nor would many persons have expected that,

by the year 2000, a set of voluntary standards for

environmental management systems (EMs) for

business and industry would be in place in many

of those same countries, with more than 5,000

applicants certified as meeting those standards.

The processes of EIA and EMs might be per-

ceived as two sides of the same coin. However,

they developed from quite separate origins, and so

far very little consideration has been given to the

potential procedural and substantive benefits of

integrating these two processes. In this article, we

would like to invite

that consideration.

Background The essential el-

ements of EIA, and

the variety of ways

it has been applied

in both developed

and developing countries, have been summarized

by Robinson (1993), Wood (1997), and Lee and

George (2000), among others.

Most of the countries that have embraced EIA

have adopted specific mandatory planning proce-

dures for the evaluation of proposed actions that

may significantly affect environmental quality.

These procedures usually include a preliminary

screening for significance of potential impacts; a

scoping process to consider alternatives and to

focus subsequent analysis on the most significant

impacts; and preparation of an environmental as-

sessment document (variously labeled as an EA,

EIS, or EIA report) which is subject to some form

of public review and comment, prior to reaching

Environmental Quality Management / Summer 2002 / 1

© 2002 Wiley Periodicals, Inc.Published online in Wiley InterScience (www.interscience.wiley.com).DOI: 10.1002/tqem.10036

Charles H. Eccleston and

Robert B. Smythe

Integrating EnvironmentalImpact Assessment withEnvironmentalManagement Systems

A synergistic process for improv-

ing environmental quality

Charles H. Eccleston and Robert B. Smythe2 / Summer 2002 / Environmental Quality Management

a decision on whether to proceed with the pro-

posed action. These EIA procedures, however,

typically lack substantive standards or require-

ments for environmental protection—such as re-

quirements that actions must have net environ-

mental benefits or must incorporate measures

that minimize environmental damage.

During the same time period that EIA was

spreading across the globe, the growth of world

trade and the expansion of international markets

led business and industrial leaders to raise con-

cerns over the proliferation of varying standards

for manufacturing, trade, and product testing.

In 1979, the International Organization for

Standardization (ISO), a private-sector inter-

national institution

based in Geneva,

began an effort to de-

velop a set of interna-

tional voluntary stan-

dards for product

manufacturing and

distribution. The ISO

9000 series, issued in 1987, sets standards for

business management processes; registration

under ISO 9000 requires independent third-party

certification. To date, more than 100,000 busi-

nesses worldwide have achieved this registration,

which they perceive as conferring a competitive

advantage, demonstrating their dedication to

product quality (Voorhees & Woellner, 1997).

The same public concern for environmental

quality that drove the global spread of EIA also led

the ISO to focus on the need for consistent inter-

national environmental management standards.

Beginning in 1991, the ISO established an advi-

sory group to develop a series of environmental

management, auditing, and performance evalua-

tion standards, building on the 9000-series model.

After negotiations that eventually involved

delegates from 50 countries, the initial standards

in the ISO 14000 series—those for basic environ-

mental management systems (14001) and for en-

vironmental auditing standards (14010–14013)—

were adopted in September 1996.

The objective of the ISO 14000 series is to pro-

vide managers with an internationally consistent

system for measuring, controlling, and ultimately

reducing the environmental impacts generated

by their ongoing business operations. For exam-

ple, ISO 14001 describes 17 elements that must

be contained in any EMS that receives ISO certifi-

cation (Voorhees & Woellner, 1997).

Like ISO 9000, the 14000 series focuses on

management standards, not on specific perfor-

mance standards and procedures; these are left to

individual countries or businesses, which tailor

them to their specific needs. Unlike EIA, the EMS

process was designed specifically for competitive

businesses to adopt on a voluntary basis.

Some government agencies, as well as busi-

nesses in many countries, have already had their

environmental management systems certified

under ISO 14001. Olson (1999) reports that as of

August 1998, nearly 5,400 such certifications had

been registered. The country with the most certi-

fications was Japan (1,100), followed by Great

Britain (650), and Germany (630). At that time,

the United States ranked ninth, with 182 certifi-

cations, although many of the larger U.S. corpo-

rations and some federal agencies (including the

Department of Energy and the Department of De-

fense) had begun to use ISO 14000 standards as

informal benchmarks in their ongoing develop-

ment of EMSs.

The Dilemma It thus appears that a large number of coun-

tries, both developed and developing, are engaged

in implementing both the EIA process and at least

some key elements of the EMS process as articu-

lated in the ISO 14000 standards. Questions have

been raised as to whether these two processes are

either complementary or redundant.

Questions have been raised as towhether these two processes areeither complementary or redundant.

Environmental Quality Management / Summer 2002 / 3Integrating Environmental Impact Assessment with Environmental Management Systems

of environmentally preferable alternatives; lack

of meaningful public participation; and failure to

implement monitoring, mitigation, and compli-

ance measures recommended during the EIA

process in required (and enforceable) compo-

nents of the operational stages of the approved

action (Lee, 2000).

As described in this article, strong parallels exist

between the goals and requirements of most EIA

processes and the specifications for implementing

an ISO 14000–consistent EMS. Integrating the EIA

and EMS processes could yield new opportunities

for infusing substantive environmental goals into

both government planning and business decision

making. Such a strategy

could lead to more ef-

fective planning and

improved environmen-

tal protection, while

streamlining compli-

ance and enhancing

business competitive-

ness in an increasingly

global marketplace.

How the EMS and EIA Processes CanComplement Each Other

In this article, the term “EMS” is used to mean

a process that is consistent with the ISO 14000 se-

ries of standards. Prudence must be exercised in

order to develop an effective integrated process

that satisfies the rigors of an international stan-

dard and/or certification, without detracting

from operational efficiency.

While the generalized strategy outlined below

is directed at integrating an EIA process with an

ISO 14000 EMS, it could also be followed in inte-

grating other forms of EMSs that contain stan-

dards and elements similar to those found in the

ISO 14000 series.

As the reader will soon find, the goals and re-

quirements of most international EIA processes

EMS is entirely voluntary; it is designed to en-

hance the overall efficiency and environmental

acceptability of individual enterprises, public as

well as private. EIA, in contrast, is usually a gov-

ernment requirement—which also, of course, can

affect businesses directly and indirectly.

Recognizing these important distinctions, is

the EMS process simply an operational extension

of EIA? Is an EIA process really necessary if an

EMS is already in place that would oversee con-

struction and/or operation of a proposed govern-

ment project or industrial activity?

Conversely, is the EMS process alone capable of

accomplishing such environmental objectives as

the planning and evaluation of siting and design

alternatives, and ensuring public participation in

the pre-approval stages of a proposed action?

The following discussion examines these is-

sues and outlines a comprehensive strategy for in-

tegrating the EIA process with an ISO 14000–con-

sistent EMS so as to promote efficiency, minimize

redundancy, and enhance environmental protec-

tion. This strategy is a generalization of a strategy

first published by one of the authors (Eccleston,

1998, 2000) for integrating NEPA with an ISO

14000–consistent EMS. The following generalized

strategy builds on the original concept and is

specifically designed with adaptability in mind,

so that it can be used in most nations and can be

applied to virtually any level of program or proj-

ect planning and management.

Properly implemented, EIA is a proven and

powerful tool for integrating environmental com-

ponents into natural resource development poli-

cies, programs, and projects, contributing to the

essential long-term goal of sustainable develop-

ment. Unfortunately, the effectiveness of many

EIA processes (including the NEPA process of the

United States) is often less than optimal.

This diminished effectiveness commonly re-

sults from failure to implement the process early

in the planning stages; inadequate consideration

Integrating the EIA and EMSprocesses could yield new opportu-nities for infusing substantive envi-

ronmental goals into both govern-ment planning and business

decision making.


and those of most EMSs are generally compatible.

Equally important, their relative strengths and

weaknesses generally tend to complement one

another. That is, the weaknesses of one system

tend to be offset by the strengths of the other.

Exhibit 1 summarizes the similarities and

synergistic strengths that can be brought together

in an integrated EIA/EMS. These similarities and

strengths are outlined and compared in the fol-

lowing sections.

Various Types of “Actions” May Be Subject toan EIA Review

Specific EIA requirements vary from country

to country. In general, however, formulating a

government policy, plan, program, or project (or

granting government approval to a private-sector

activity) that has the potential for causing envi-

ronmental effects or impacts may constitute an

“action” subject to predecision review under a

nation’s EIA process.

Exhibit 1. How EIA and EMS Can Complement Each Other

Characteristics Typical EIA Processes ISO 14000–Consistent EMS

Goal The goal of an EIA is generally to provide environmental ISO’s goal is to provide environmental protection by protection by ensuring that environmental factors are identifying impacts. Its continual improvement system considered during the early planning process. is used to reduce these impacts.

Mandate The EIA process often lacks a legally binding Substantive actions are expected to be taken, which lead substantive mandate to protect the environment. to continual improvement in environmental protection.

Planning function A comprehensive environmental planning process is A planning function requires a system for ensuringfollowed, but it typically lacks an environmental quality that decisions are appropriately implemented.system for ensuring that the decisions are properly However, it does not prescribe a detailed process implemented. for performing the planning function.

External input A detailed formal “public scoping” process for A procedure (not public) is required to record andidentifying significant impacts and eliminating respond to external parties, but it does not includenonsignificant issues is generally specified. specific steps for public involvement.

Other environmental Other environmental review processes and objectives A top-level environmental policy is required, includingrequirements such as pollution prevention measures, environmental an ongoing commitment to preventing pollution,

justice, and biodiversity are either required to be which is very broadly defined. The policy does not integrated with the EIA or may be done so specifically address integration of the EMS with other voluntarily. laws and policies.

Life cycle An analysis of “reasonably foreseeable” impacts over Details of how to perform a life-cycle analysis arethe “life cycle” of the action is typically required. described in the ISO 14040 series.

Impact assessment EIA processes often include detailed directions for An investigation of “environmental aspects" is required.requirements performing an analysis of direct, indirect, and However, the requirements for performing this

cumulative impacts. investigation generally lack specificity regarding scope or content.

Accumulated Many years of experience have been accumulated in This is a relatively new process. Only limited environmental the planning and analysis of significant environmental experience has been accumulated in the planning experience impacts through different EIA processes worldwide. and analysis of significant environmental issues.

Significance Specific factors for determining the significance of No detailed direction for interpreting or determining environmental impacts are frequently specified in the the meaning of "significance" is provided.EIA guidance documents or other relevant regulations.

Mitigation Mitigation measures are generally required to be EMS provides a system for ensuring that mitigation identified and analyzed as part of the EIA planning measures are implemented during the operation of the processes. project or policy.

Monitoring EIA processes frequently encourage (but infrequently Monitoring is mandated as part of the continual require) post-monitoring measures. improvement cycle.

Continual Most EIA processes lack a specific component for A continual improvement process is a basic concept improvement continually improving quality. inherent in an EMS.


pare other required analyses and studies con-

currently with, and integrated with, the envi-

ronmental impact statement . . .” (40 CFR

1501.7[a][6]); and

— “[a]ny environmental document in compli-

ance with NEPA may be combined with any

other agency document . . .” (40 CFR 1506.4)

Most EIA processes include detailed analytical

and documentation requirements. With minor

modifications, these EIA requirements can also be

applied to the process of developing an EMS to

ensure that it incorporates or recognizes other en-

vironmental compliance requirements.

• Linking the Planning Functions of EIA andEMS Planning is not only mandatory, it is also

one of the most basic components underlying

EMS. Surprisingly, however, ISO 14000 provides

only limited direction for performing the plan-

ning function. For example, basic EIA proce-

dures and requirements, such as the following,

are only vaguely implied or defined under ISO

14000 procedures:

— performing scoping, including consideration

of both site and design alternatives;

For example, as summarized in Exhibit 2, es-

tablishment of federal policies and plans in the

United States is an “action” subject to the re-

quirements of the U.S. NEPA statute if the action

may have direct or indirect effects on “the qual-

ity of the human environment.”

Integrating the Analytical Components of EIAand EMS

• Environmental Compliance Requirements The EIA regulations of many nations require

their agencies to integrate the EIA process with

other environmental compliance requirements

(e.g., laws, policies, permits, or regulatory re-

quirements) so that the environmental review

procedures for a proposed action run concur-

rently, thereby reducing delays and holding

down the cost of compliance. For example, the

U.S. government’s NEPA Regulations (CEQ, 1978)

provide that:

— federal agencies must “integrate the require-

ments of NEPA with other planning and envi-

ronmental review procedures . . .” (40 CFR

1500.2[c]);

— they must “identify other environmental re-

view and consultation requirements . . . pre-

Exhibit 2. U.S. Federal Government Actions Potentially Subject to NEPA

Federal actions tend to fall within one of the following categories (40 CFR 1508.18[b]):

(1) Adoption of official policy, formal documents establishing an agency's policies which will result in or sub-stantially alter agency programs.

(2) Adoption of formal plans, such as official documents prepared or approved by federal agencies which guideor prescribe alternative uses of federal resources, upon which future agency actions will be based.

(3) Adoption of programs, such as a group of concerted actions to implement a specific policy or plan . . .

(4) Approval of specific projects . . .

“projects and programs . . . new or revised agency rules, regulations, plans, policies, or procedures (40 1508.18[a]).”

“Actions include new and continuing activities, including projects and programs entirely or partly financed, assisted,conducted, regulated, or approved by federal agencies; new or revised agency rules, regulations, plans, policies, orprocedures; and legislative proposals (1508.18[a]). . . .”


— evaluating potential environmental impacts;

— defining temporal and spatial bounds;

— interpreting impact significance;

— assuring public participation.

Most national EIA processes contain rather

prescriptive directions for ensuring that these key

elements of the planning process are carefully

conducted so as to provide decision makers with

timely, accurate information sufficient to reach

an informed decision.

If the analysis of these elements from the EIA

process is explicitly considered in the subsequent

formulation of an EMS, then integration of the

planning and operational phases can be more ef-

fectively linked. In the

EIA process, the pur-

pose of such analysis is

to provide information

that supports informed

decision making. For

example, the U.S. NEPA

regulations provide de-

tailed requirements for

performing a compre-

hensive analysis of di-

rect, indirect, and cumulative impacts.

ISO 14000 requires that an EMS include in-

vestigation of significant “environmental as-

pects,” which are specific activities that affect the

environment. Although these environmental as-

pects must be determined, rigorous evaluation of

their resulting consequences or impacts on envi-

ronmental resources is not required.

Nor is the EMS process well suited to the early-

stage evaluation of potential facility siting or de-

sign alternatives. EMS was instead designed as a

tool for businesses operating under whatever envi-

ronmental assessment or other regulatory require-

ments governments might have established, if any.

From a planning perspective, most EIA

processes provide a more rigorous procedure for

ensuring that the potential environmental im-

pacts are identified and evaluated, and that alter-

natives are rigorously considered, before a deci-

sion is made to pursue an action.

• Life-Cycle Analysis To the extent practical, most EIA processes re-

quire that the impact analysis cover the antici-

pated life cycle of an action. Both short- and

long-term effects must typically be considered.

For example, in the United States the “reasonably

foreseeable” impacts of future actions must be

identified and evaluated to the extent feasible.

Most EIA procedures, however, do not contain

rigorous requirements that are enforceable during

the operational phases of an approved action.

Similarly, the ISO 14040 series describes in

detail how a life-cycle analysis should be per-

formed. Since an EMS is a continuing process

rather than a one-time event, it can have a

much greater potential for effectively addressing

environmental impacts over the life cycle of a

project. Integrating such requirements with the

EMS could reduce costs and achieve more effec-

tive compliance.

• Pollution Prevention Some governments have issued direction for

incorporating pollution prevention measures

with their EIA process. For example, in the

United States, the President’s Council on Envi-

ronmental Quality (CEQ, 1993) has issued guid-

ance indicating that, where appropriate, pollu-

tion prevention measures are to be coordinated

with and included in the scope of an environ-

mental impact analysis.

ISO 14000 speaks to the merits of addressing

pollution prevention in an EMS, but mainly from

the standpoint of establishing a top-level policy

committed to pollution prevention.

Under an integrated strategy, EIA processes

may provide a practical framework for evaluating

Most EIA processes provide a morerigorous procedure for ensuring thatthe potential environmental impactsare identified and evaluated, andthat alternatives are rigorously con-sidered, before a decision is madeto pursue an action.


In the United States, NEPA’s contribution to

EIA derives not from any substantive mandate

to choose an environmentally beneficial alter-

native, but instead from its procedural mandate

requiring decision makers to rigorously evaluate

and consider the environmental impacts of po-

tential actions, just as they would analyze

other, more traditional factors such as eco-

nomic costs, design options, and construction

schedules.

In contrast, an EMS involves a commitment

to take substantive actions to improve environ-

mental quality. Moreover, environmentally bene-

ficial actions are to be

implemented using a

cyclical process of con-

tinual environmental

improvement. Thus,

an EMS provides a

mechanism for enforc-

ing the substantive environmental mandate that

many EIA procedures lack.

Additionally, many EIA processes require the

investigation of mitigation measures to reduce or

offset anticipated adverse environmental im-

pacts. However, these procedures often place no

substantive mandate on decision makers to carry

out the mitigation measures.

Again, this weakness in the EIA process is off-

set in the EMS process, which requires organiza-

tions to establish target objectives for ongoing

improvements in environmental performance.

Reaching such targets often necessitates imple-

menting actions similar to the mitigation mea-

sures that are described in many EIA documents,

but which all too often are neglected after the

proposal is approved.

Thus, while EIA processes frequently include

relatively rigorous requirements for planning and

for developing mitigation measures, the EMS

process can and should provide the “teeth” for

implementing such plans and such measures.

and integrating a comprehensive pollution pre-

vention plan, while the EMS process provides a

top-down policy for ensuring that pollution pre-

vention measures are actually incorporated on a

continuous basis during the operational phases.

The two processes have similar integration

goals: EIA seeks integration of environmental

considerations into other planning and decision

making, while EMS seeks to integrate the moni-

toring, reporting, training, feedback, and self-cor-

recting process into every aspect of the operation.

• Public Participation The choice of alternatives to be analyzed in an

environmental planning process can be highly

dependent on the concerns of stakeholders. Not

surprisingly, public participation is a key compo-

nent of EIA processes in many countries (Bisset,

2000), although all too often government minis-

ters and business leaders unfamiliar with the ben-

efits that can result from seeking genuine public

involvement initially view it with a distinct lack

of enthusiasm.

In contrast, the ISO 14000 standards for EMS

have no explicit requirement for public partici-

pation, only a requirement to make the overall

policy document available to the public and to

develop a plan for external communications

and inquiries.

This is yet another illustration of how the ex-

perience gained through the EIA public participa-

tion and scoping process could compensate for

the absence of such a component in the ISO

14000 EMS.

Substantive versus Procedural Compliance Many EIA processes are largely procedural re-

quirements. That is, while the EIA process must be

performed, decision makers are not obligated to

select an environmentally beneficial alternative,

or to demonstrate that their decision conforms to

established environmental goals or standards.

Weakness in the EIA process is off-set in the EMS process.


Significance Determining the significance of environmental

impacts is a theme central to effective EMS, as

well as to virtually all EIA processes. Many EIA

processes, such as NEPA, bring years of experience

to bear on the problem of determining “signifi-

cance.” For example, the U.S. NEPA regulations

not only define significance in terms of context

and intensity, but also specify ten factors to be

used in reaching determinations regarding the

potential significance of an environmental im-

pact (40 CFR 1508.27).

This level of specificity is lacking in the ISO

14000 standards for

EMS. Under ISO 14001,

“significance” is only

vaguely defined; no

factors are explicitly

prescribed for assisting

decision makers in de-

termining if an envi-

ronmental aspect is

significant.

Monitoring and Continuous Improvement Many EIA processes either mandate or en-

courage ongoing monitoring of environmental

conditions to assure that potentially significant

adverse impacts are avoided or controlled. The

EIA procedures of many countries strongly en-

courage, and in some instances mandate, the in-

clusion of environmental monitoring provisions

as part of the EIA documentation. The World

Bank has recently issued a policy document that

outlines the key elements that should be in-

cluded in a post-approval environmental man-

agement plan, or EMP (World Bank, 1999).

Relatively few countries, however, require the

explicit production of a full-fledged EMP, with

enforceable schedules and reporting procedures,

as a condition of approval to enter the construc-

tion and operation phase (George, 2000). In the

absence of an enforceable EMP requirement, the

courts and other regulatory reviewing authorities

have been reluctant to compel monitoring or

mitigation measures.

In contrast, ongoing monitoring, and opera-

tional improvement in response to that monitor-

ing, are basic components of an EMS. Regular

monitoring of, and reporting on, environmental

conditions provide a manager with the basis for

making operational changes to reduce adverse

impacts and avoid the costs and delays that are

often associated with them. This in turn provides

the manager with the necessary data to support

continued certification under ISO 14000.

Where a proposed project or other action has

been through an EIA process, the EIA report itself

provides an obvious foundation for developing a

list of potential environmental impacts to be

monitored, as well as a reference for establishing

performance targets to be met within the EMS.

Conversely, where the EIA process for a pro-

posed action requires an EMP, the EMS itself may

be included in, or submitted with, the EIA report.

George (2000) states that such a requirement “has

recently been included in guidance for the UK’s

oil and gas sector, and may well be equally appli-

cable for similar projects in low and middle in-

come countries.”

While this may seem to raise the familiar “cart

before horse” objection, in practice there is no

reason why the EIA and EMS processes should

not proceed in tandem, with the goal being a

properly integrated EIA/EMS, to ensure that mon-

itoring plans are effectively designed and exe-

cuted. EIA/EMS integration is especially appropri-

ate where government decisions are required, and

where government (or government-regulated) en-

terprises will carry out the operations. The EIA

can identify the kinds of significant impacts that

an EMS should address, and the EMS can then en-

sure that adequate monitoring, reporting, and

self-correcting take place.

The EIA can identify the kinds ofsignificant impacts that an EMSshould address, and the EMS canthen ensure that adequate monitor-ing, reporting, and self-correctingtake place.


Policy, Planning, Analysis, and Decision-Making Phase

The policy, planning, analysis, and decision-

making phase is represented by the first four

blocks shown in Exhibit 4. These four steps are

performed primarily through the agency’s EIA

process. The remaining two steps are primarily

performed through the standard EMS process.

A conscious effort to link each process to the

other is necessary to achieve the benefits of inte-

gration. A good EIA can serve to identify the key

environmental issues and can recommend ways of

avoiding or reducing adverse impacts; but if it lacks

Strategy for Integrating EIA with EMS Exhibit 3 depicts a simplified overview of a

typical EMS. In a properly integrated EIA/EMS

process, the EIA element fulfills the requirements

of the first two boxes shown in this exhibit.

Exhibit 4 illustrates a generalized strategy

for integrating an EIA with an EMS. As shown

in this exhibit, the strategy is composed of

three discrete phases: (1) centralized policy,

planning, analysis, and decision making; (2)

implementation; and (3) environmental moni-

toring and improvement. These three phases

are described below.

Exhibit 3. Simplified Overview of a Typical Environmental Management System


effective provisions for continuous monitoring and

improvement, its objectives may not be met. An

EMS may set forth a detailed process for monitor-

ing and reducing adverse impacts, but if it is not

supported by an objective assessment of potential

impacts conducted via an EIA process, it may not

effectively monitor the appropriate parameters or

reduce the most significant adverse impacts.

• Establishing a Policy As depicted by the first block in Exhibit 4,

the proposed integration strategy is initiated by

the step of establishing a high-level organiza-

tional environmental policy and a commitment

to maintaining environmental quality during

all phases of activity over the life of the pro-

posed action.

Exhibit 4. Conceptual Framework for Integrating an EIA with EMS


A broad, strategic-level environmental manage-

ment plan (EMP) might be prepared for a major

program or installation; in other cases, a site-spe-

cific facility implementation plan (FIP) might be

prepared for a particular facility, operation, or a

project-specific action. Both the EMP and the FIP

can incorporate, at different levels of specificity, an

array of related environmental issues such as pol-

lution prevention, safety procedures, habitat man-

agement practices, sustainable development, and

other related goals or disciplines.

Implementation Phase As depicted by the fifth block shown in Exhibit

4, once a final decision

has been reached, an ef-

fort is begun to imple-

ment the plan. In this

phase the standards

and procedures to be

followed will be prima-

rily those set forth in

the EMS process.

For a multi-facility

plan, a centralized

planning function

might be used to coordinate implementation of

the plan within the respective facilities and oper-

ations. At the lower facility or operational level,

environmental compliance officers (ECOs) or

equivalents could be assigned responsibility for

preparing a more detailed site-specific facility im-

plementation plan for implementing the EMP.

Thus the EMP could provide higher-level di-

rection and constraints that the FIP must meet.

Individual FIPs would be “tiered” from the EMP,

providing facility/specific direction for imple-

menting results of the planning process by way of

the EMS. A centralized planning office could be

assigned responsibility for approving each FIP so

as to ensure continuity and consistency. Imple-

mentation problems and “cross-cutting” issues

• Planning The initial step is followed by development of

a specific plan for implementing the environmen-

tal policy (second block, Exhibit 4). Drawing on

expertise and experience from a diverse array of

planning requirements and entities, an interdisci-

plinary effort is used in developing plans and al-

ternatives. Here, the EIA process provides the in-

terdisciplinary framework for integrating and

coordinating all early environmental planning,

public participation, reviews, and technical analy-

ses necessary to support the eventual decision.

• Identifying and Analyzing SignificantImpacts As depicted by the third block of Exhibit 4,

the EIA public scoping process is used to obtain

public input to develop alternatives and to sort

significant from nonsignificant issues.

An EIA analysis is prepared for projects/plans

having a potential to significantly impact the en-

vironment. Proposed actions, alternatives, and

impacts are evaluated pursuant to established

EIA procedures and requirements and any addi-

tional EMS requirements. For example, such an

analysis can also be used to prepare an emer-

gency response plan, thus satisfying an impor-

tant EMS requirement.

A preliminary EMS may be prepared and cir-

culated with, or as part of, the EIA analysis during

the public review and comment phase. Both the

EIA and the EMS are then revised in response to

comments received.

• Decision Making The completed analysis—probably in the

form of an integrated EIA/EMS document—is

summarized and presented to the appropriate de-

cision makers for final pre-approval review

(fourth block, Exhibit 4). On completing the re-

view, a final decision is made with respect to the

particular course of action that will be taken.

A broad, strategic-level environ-mental management plan (EMP)

might be prepared for a major pro-gram or installation; in other cases,a site-specific facility implementa-

tion plan (FIP) might be preparedfor a particular facility, operation,

or a project-specific action.


could also be elevated to the centralized planning

office for resolution.

Consistent with ISO 14000 requirements, the

EMS could help en-

sure that job-appro-

priate training is pro-

vided to all relevant

employees, thus help-

ing to assure that the

EMPs and FIPs are cor-

rectly implemented.

In this example, defin-

ing and tracking the

appropriate training requirements could be a cen-

tralized function, while actually implementing

the training requirements could be an operations-

specific function.

Monitoring and Improvement Phase Monitoring data would be collected as speci-

fied in the EMS, based on the EIA’s prior identifi-

cation of potential impacts. These data are eval-

uated to verify compliance and the effectiveness

of the EMS in meeting the established policy and

plan (sixth block of Exhibit 4).

A centralized environmental oversight office

could be assigned responsibility for performing

reviews and for monitoring facility and opera-

tional compliance. An ECO (or equivalent) could

be assigned responsibility for preparing and

transmitting input and status reports to an over-

sight office. The oversight office could perform

audits periodically to verify the adequacy of com-

pliance with the requirements of the EIA/EMS.

As appropriate, the EMS will be revised to cor-

rect deficiencies identified during monitoring

(see loop branching to box labeled “Corrective

Action” on Exhibit 4). Substantial changes in the

overall EMS might be made at the centralized

planning level, while less significant changes

could be implemented at the facility level by re-

vising the FIP.

Aims of EIA/EMS Integration Ultimately, the goal behind this integration of

EIA with EMS is to ensure that initial adverse im-

pacts will be no greater than the levels set out as

acceptable in the plan, and will be reduced by

continual design improvements, process refine-

ments, and mitigation measures.

Such a process achieves the environmental

quality goals of both EIA and EMS because it en-

sures that adverse impacts are anticipated and con-

trolled (which is the objective of EIA), and that any

remaining significant impacts are reduced or elim-

inated through a continuous improvement cycle

(which is the hallmark of an EMS).

Summary and Conclusion The principal objective of this article has been

to encourage practitioners of both EIA and EMS

to consider the potential advantages of explicitly

integrating the two processes, and to outline a

conceptual framework for doing so. The advan-

tages potentially include savings in time, costs,

and controversy, and improvements in the long-

term achievement and maintenance of environ-

mental quality.

We have argued that the two processes are

complementary, and that adopting the relative

strengths of each process can largely offset their

respective relative weaknesses. The EIA process,

which focuses on pre-approval planning and de-

sign, often lacks a legally binding substantive

mandate to protect the environment in the oper-

ational phases of an approved action. In contrast,

the EMS process requires ongoing monitoring

and substantive actions to be taken, leading to

continual environmental improvement.

But simply conducting both processes,

whether simultaneously or in sequence, does not

automatically achieve these benefits. In reality,

planners and managers must develop a detailed

and carefully thought-out strategy for con-

sciously merging the two processes in order to

The advantages potentially includesavings in time, costs, and contro-versy, and improvements in thelong-term achievement and mainte-nance of environmental quality.


the President. (1993, January 29). Guidance on pollution pre-vention and the National Environmental Policy Act, 58 Fed.Reg. 6478.

Eccleston, C.H. (1998, Spring). A strategy for integrating NEPAwith EMS and ISO 14000. Environmental Quality Manage-ment, 7(3), 9–17.

Eccleston, C.H. (2000). Environmental impact statements: Acomprehensive guide to project and strategic planning (chap-ter 4). New York: John Wiley & Sons.

George, C. (2000). Environmental monitoring, managementand auditing. In N. Lee & C. George (Eds.), Environmental as-sessment in developing and transitional countries (chapter11). New York: John Wiley & Sons.

Lee, N. (2000). Integrating appraisals and decision-making. InN. Lee & C. George (Eds.), Environmental assessment in de-veloping and transitional countries (chapter 10). New York:John Wiley & Sons.

Lee, N., & George, C. (Eds.). (2000). Environmental assess-ment in developing and transitional countries. New York:John Wiley & Sons.

National Environmental Policy Act of 1969, as amended. 42U.S.C. sections 4321–4347 (January 1, 1970).

Olson, S. (1999). International environmental standardshandbook. Boca Raton, FL: Lewis Publishers.

Robinson, N. (1993). EIA abroad: The comparative andtransnational experience. In S. Hildebrand & J. Cannon (Eds.),Environmental analysis: The NEPA experience. Boca Raton,FL: Lewis Publishers.

Voorhees, J., & Woellner, R. (1997). International environ-mental risk management: ISO 14000 and the systems ap-proach. Boca Raton, FL: Lewis Publishers.

Wood, C. (1997). What has NEPA wrought abroad? In R. Clark& L. Canter (Eds.), Environmental policy and NEPA: Past,present, and future (chapter 7). Boca Raton, FL: St. Lucie Press.

World Bank. (1999). Operational Policy OP 4.01, Annex C: En-vironmental management plan. Washington, DC: World Bank.

truly gain from the relative strengths of each sys-

tem. We have suggested herein a generalized

framework for doing so.

When effectively integrated, the combined

EIA/EMS process incorporates the EIA’s up-front

consideration of alternatives, participation by the

public, and analysis of potential impacts with the

EMS’s ongoing commitment to making decisions

and taking substantive actions to protect envi-

ronmental quality throughout the life cycle of

the activity. The EMS component thereby pro-

vides a mechanism for applying the substantive

environmental mandate that many environmen-

tal practitioners seek, but which EIA procedures

still generally lack. The integrated process should

help to achieve the globally sought goals of im-

proved environmental quality and sustainable

development.

ReferencesBisset, R. (2000). Methods of consultation and public partici-pation. In N. Lee & C. George (Eds.), Environmental assess-ment in developing and transitional countries (chapter 9).New York: John Wiley & Sons.

Council on Environmental Quality (CEQ), Executive Office ofthe President. (1978). Regulations for implementing the pro-cedural provisions of the National Environmental Policy Act,40 C.F.R. Parts 1500–1508.

Council on Environmental Quality (CEQ), Executive Office of

Charles H. Eccleston is a Certified Environmental Professional (CEP) and one of the leading authorities on the NEPAprocess. He is the author of three leading textbooks on NEPA published by John Wiley & Sons and CRC Press. His con-sulting company, Environmental Planning and NEPA Services, specializes in applying modern tools and techniques forstreamlining processes, and preparing effective NEPA and EIA analyses. He can be contacted at [email protected] Web site is located at http://www.nepa-planning.com. Robert B. Smythe, Ph.D., is a consulting ecologist with expert-ise in environmental assessment, natural resource management, and environmental policy. He is the owner/principal of Po-tomac Resource Consultants. Dr. Smythe has conducted numerous studies and training programs, both within the UnitedStates and abroad. He is also the editor of NEPA News, a quarterly newsletter on the U.S. National Environmental PolicyAct. He can be contacted at [email protected].

Documents

Integrating Environmental Impact Assessment with Environmental Management Systems