Environmental Management Plan (EMP) – Key Requirements for Development
An Environmental Management Plan or EMP is a key tool to ensuring appropriate management practices are implemented during your project or operations. An effectively implemented EMP will ensure compliance with legislation and approval conditions as well as implementing best practice environmental management.
An EMP describes how your project or operations may impact on the environment and sets commitments on how these impacts will be avoided, minimised and managed so that they are environmentally acceptable.
This article details the key requirements of developing an EMP and will cover the following topics:
What is an Environmental Management Plan?
An Environment Management Plan is a site or project-specific plan developed to ensure that appropriate environmental management practices are followed during construction and/or operations. An EMP is a guidance document used to plan, implement, measure and achieve compliance with the environmental protection and mitigation requirements. These compliance requirements include relevant legislation, project-specific approvals and other stakeholder requirements.
After being developed, the EMP may be required to be submitted to a regulator, client or other interested parties for approval. When it has been approved for the works, it becomes a compliance document required to be implemented by all management, workers, contractors and subcontractors. Therefore, the EMP should be developed to ensure that all personnel can understand the potential environmental risks, and implement the controls to manage these risks.
To ensure that the EMP is effectively managing environmental risks, the Plan should specify how management measures will be monitored and reviewed. This should include the methodology, frequency and duration of monitoring and review activities. It should also include triggers under which corrective actions are taken.
What goes in an Environmental Management Plan?
The size and the complexity of a project will influence how the EMP is developed, that is the format of the plan and level of information that is included.
For small projects, such as projects small in area with no complex environmental issues, the structure of the EMP may be organised into checklists or tables. For large projects, such as multiple sites and/or complex environmental issues, multiple plans or tables may be required based on each stage; each site or operation; and/or environmental issues.
In simple terms, the main focus of an EMP is the development of a plan that is specific to the project or operations and outlines:
- Environmental issues
- Potential outcome of these issues
- How these issues will be managed through monitoring and implementation
In accordance with the Australian Government Environmental Management Plan Guidelines (2014) an EMP should be:
- Balanced, objective and concise
- Written in a way that is easily understood by other parties
- Clearly present how conclusions about risks have been reached
- Ensure responsibility for the content and commitments contained in the plan
- State any limitations or uncertainties that apply, or should apply, to the use of the information in the EMP
Key Components of an EMP
Described below are the four key components of an Environmental Management Plan:
This section sets the context of the project and the management plan. This typically includes the following information:
Introduction: a brief description of the project’s background.
Project Description: define the nature and scope of the project which may include location, activities and timing/scheduling.
Objectives: this relates to the overall project and environmental best practices.
Environmental Policy: overarching environmental commitments.
2. Environmental Management
This section sets the requirements and processes for implementing the management plan and includes:
Environmental Management Structure and Responsibility: organisational structure responsible for environmental management for the project.
Approvals and Regulation Requirements: tables or lists of relevant legislation, conditions of approvals or consent, and any other requirements such as stakeholder agreements, environmental management system requirements, etc.
Reporting: description of reporting requirements including under legislation, construction monitoring, non-compliance and auditing.
Environmental Training: both general environmental awareness training and training about their responsibilities under the EMP.
Emergency Contacts and Response: procedures to be followed in the event of an environmental emergency.
The section identifies the environmental risks of the project and how they will be managed. This typically includes the following steps:
- List all of the activities to be undertaken
- Identify the actual and potential environmental impacts associated with each of the activities
- Risk assess each of the environmental impacts to determine significant impacts
- Determine environmental management controls and monitoring to prevent or minimise environmental impacts
Further information is provided in the next section regarding the content of this Implementation section.
4. Monitor and Review
An EMP is not static. It is a working document that requires reviews and amendments during the life of the project. This section should document how the environmental management activities will be monitored and reviewed to ensure the controls are effective and applicable to the project activities.
Example of a Construction Environmental Management Plan (CEMP)
For small projects or during the construction phase of a project, the ‘Implementation’ section of the Plan may be organised using an issues-based format. The issues-based format involves organising the environmental impacts, management activities and controls information under each identified environmental issue. This could be written as tables, separate sections of the Plan or separate Sub-plans.
The typical environmental issues included in a Construction Environmental Management Plan:
- Erosion and sedimentation
- Water quality
- Air quality
- Flora and fauna
- Indigenous heritage
- Non-indigenous heritage
- Noise and vibration
- Hazardous materials
For large projects carried out over extended periods, the ‘Implementation’ section of the EMP may be developed using a stage-based format. This involves documenting the environmental issues and control measures for each stage of a project. For example, the planning and design stage, the construction stage and the operational stage. Typically these stages would be developed as separate plans.
Here is a project example we recently completed for a road embankment stabilisation project. We developed the Construction Environment Management Plan and provided implementation support to PCA Ground Engineering.
Benefits of an Environmental Management Plan
An Environment Management Plan (EMP) identifies the actual and potential environmental risks that may be caused by the project or operation and identifies controls to manage these risks before they result in environmental harm.
An EMP is a valuable tool to:
- Define who, what, where and when environmental management and mitigation measures are to be implemented
- Provide stakeholders, including government agencies, contractors and other interested parties, with better insight and control over the environmental aspects
- Demonstrate due diligence
Overall, an EMP that has been specifically developed for your project or operations is key to ensuring your environmental risks are identified and appropriate management practices implemented. A well developed and effectively implemented EMP will ensure compliance with your regulatory requirements as well as implementing best practice environmental management.
If you are looking for an EMP for your project, contact us to have one of our specialists support your request.