Background Environmental Impact Assessment has made commitments to: • Meet defined standards • Implement defined mitigation measures • Limit defined impacts • Monitor compliance and environment Approval will include these as conditions to be attached to consents.
Environmental Management Plan: Implementation Plan for meeting Commitments and Conditions of Consents • Regulators think in terms of environmental compartments – consent organised in terms of Air, Water, Waste. • Operators think in terms of Activity – Management Plan organised in terms of operation and management structure.
Objective • A stand alone tool for the management of potential adverse impacts and to enhance project benefits • Activity based mitigation of impacts identified in the ESIA
Responsible Parties • Each Phase of the project will be implemented by different groups • Construction: Contractors • Operations: Company/outsourcing • HSE will not be the main focus of each groups activity • Expertise in HSE may be lacking
Barriers to Implementation • Clear definition of Responsible Parties • Clear communication of requirements • Clear definition of KPIs, monitoring & reporting • Clear definition of consequences of non-compliance • Irregular or inappropriate internal checks (audits) • Not included in tender documents – contracts
Content of Environmental Management Plan • Targets and Standards • Procedures • Activities • Aspects • Mitigation • KPIs • Reporting • Organization and Responsibilities • Monitoring and Reporting • Auditing • Management Review • Specific Plans
Targets and Standards • Taken from consents & company requirements • Emissions and effluent standards • Environmental Quality standards • Frequency of monitoring • Reporting requirements
Procedures Day to day operations • Organized by Activity • Lists impacts • Defines mitigation measures • Defines KPIs • Define what is to be reported and when Basis of audit protocols
Organisation and Responsibilities • Who is accountable? • Who is responsible for each activity? • Tendering and Contracting • Reporting Lines
Monitoring and Reporting As per Management Plan Requirement Refer to Environmental Monitoring Plan
Auditing Compliance: • To assess performance of operations against targets • QA/QC of monitoring programme • Check on documentation and recording • Check on equipment Scope reflected in protocols
Management Review Review team Frequency Scope: Review of results of KPIs and internal audits Response to exception reporting (including non-compliance) Response to and investigation of incidents Response to complaints Updating EMP for changes in regulations Training reviews
Specific Management Plans References to Stand Alone Plans, e.g. Solid Waste Management Plan Hazardous Waste Management Plan Occupational Health and Safety Plan Emergency Response Human Resources and Training Plan