11-4 Environmental Auditing

Environmental auditing is a review process similar to that carried out in financial accounting. Both result in a statement of facts, which certifies that practice is (or is not) in accordance with standard procedure. In the case of environmental auditing, there is an added level of interpretation, focusing on the factors of performance. The concern is to identify how the aspects, processes or systems under review can be improved.

The main techniques for conducting an environmental audit are:

  • examination of records and documentation relating to impacts, actions taken to manage them and aspects of performance;
  • interviews with management and line staff to corroborate factual information and probe areas of concern; and
  • site inspection to check that environmental measures and controls are operating as described and intended.

A distinction can be made between environmental audits conducted as part of EIA and EMS implementation, respectively. EIA related audits, typically, are ad hoc, project-by-project in approach and use non-standardised methodology. EMS audits, typically, are conducted in accordance with ISO 14001 guidance and procedures, and oriented toward continuous improvement in managing the environmental impacts of an organisation, site, process, product, supply chain or input-output balances. However, both EIA and EMS audits have objectives, elements of approach and information sources in common.

EIA audits are used to:

  • identify the impacts of project implementation;
  • verify whether or not the conditions of approval have been implemented;
  • test the accuracy of impact predictions;
  • check the effectiveness of mitigation measures; and
  • improve compliance and performance of EIA practice.

EMS audits include:

  • site audits – to examine all aspects of environmental management of a facility or operation;
  • compliance audits – to ensure an organisation or development meets pertinent legal, regulatory and voluntary or self imposed standards such as emission limits, discharge permits and operating licenses; and
  • sector or issue-specific audits – to consider key aspects of environmental management and performance, such as waste disposal, energy use, cleaner production, health and safety and supply chains.

Guidance on the conduct of EIA audits emphasises that a well-designed monitoring programme is an integral element of good practice. The ‘before and after’ data collected by baseline and effects monitoring lays down an audit ‘trail’, which allows key impacts to be tracked and statistically verified. The case example in the table below, from Hong Kong, illustrates the results of an EIA audit of a major project. It emphasises both the use of monitoring and audit to remedy deficiencies in EIA implementation and the difficulties of gathering evidence to verify their cause.

When selecting projects for a full audit, Hong Kong and international experience indicates that priority should be given to those:

  • with a high level of environmental, social, economic or political impact and visibility;
  • that can yield usable results within the existing technical and budgetary constraints; and/or
  • most at risk from deficiencies in the EIA implementation and follow up system, such as limited surveillance capability or lack of authority to enforce mitigation measures.

The case example also underlines some of the difficulties commonly experienced in the conduct of EIA monitoring and audit, including:

  • limited baseline information on variability and causal relationships;
  • qualitative and non auditable impact predictions;
  • late changes to project design and mitigation (thereby altering the basis on which predictions are made); and
  • long lead times before certain trends and impacts can be identified, for example, large scale but infrequent impacts (such as oil spills) or low dose, repetitive effects (such as exposure to heavy metals).

Other more flexible, less data demanding approaches can be taken in cases where an auditable trail of monitoring data is unavailable or insufficient. For example, ‘spot’ audits concentrate on significant impacts or priority concerns about mitigation measures. These can be undertaken either as a series of ‘rolling’ audits or a post-project analysis. An ‘impact-backwards’ methodology can be used to compare EIA prediction and mitigation with environmental effects and outcomes. Impacts are verified iteratively by consultation and field checks and traced backwards to EIA practice (comparable to an effectiveness or policy audit).

Environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SARrs
EIA section Results
Source: Sanvicens 1995.
Background A number of major projects in Hong Kong are the subject to environmental monitoring and audit (EMA) as part of EIA implementation and follow up. These programmes are carried out to ensure that the measures recommended in the EIA are actually implemented and appropriate actions are taken in cases where the impact exceeds the established limit.
Project The Chek Lap Kok Airport was built between 1991 and 1997 at a total cost of US$ 20 billion. It involved the reclamation of approx. 1250 ha site and facility development and related projects and infrastructure, including a new town of 20,000 (Tung Chung), and a 34 km high speed rail and road expressway to the city centre (involving fixed and tunnel water crossings and new terminal facilities on reclaimed land). Major areas of concern in site construction and operation included air quality, noise, water quality, waste and ecological damage resulting from dredging, dumping and reclamation.
EMA programme An EMA system was instituted to follow up on the implementation of EIA measures. The monitoring component focused on aspects of particular concern, including water quality, air emissions, noise and dust levels. At the airport reclamation site, the initial water quality monitoring network was inadequate and had to be relocated to provide a more realistic set of auditing criteria. The audit component compared actual and predicted impacts, and the effectiveness of environmental instruments, such as clauses included in licenses, contract specifications and planning and land lease conditions. The programme was carried out by developing a reference manual and database, monthly and quarterly reports on compliance and performance, respectively, and policies and procedures to be followed in the event of breaches and non-compliance.
Summary of results The implementation of EIA measures was largely dependent on the environmental awareness of the proponent’s resident site staff, and hampered by the lack of legal authority of the regulatory agency. Impact predictions were reasonably accurate (except for cumulative effects) but there were cases where the impact exceeded the worst-case scenario (e.g. mud dumping rates). The audit of the effectiveness of environmental instruments concluded that not all EIA recommendations were included in contracts, many specifications were too general, and means of enforcing or inducing compliance were insufficient. An underlying issue was the variance between the project as designed and as constructed, compromising many EIA measures and requiring renegotiation of mitigation.
Key lessons EIA documents must be prepared with the EMA requirements in mind, for example, auditable predictions and well-defined mitigation measures, with provision for their renegotiation if design and construction vary. In addition, these measures should be translated into practicable, enforceable specifications. The regulatory agency should have the necessary legal authorities for this purpose.

July 26, 2006 Uncategorized — brendan @ 11:33 am

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