Topic 11—Implementation and

Training session outline

follow up

Objectives
To explain the role and contribution of implementation and
follow up measures within the EIA process.

To understand the procedures and methods used, particularly

monitoring and auditing.

Relevance
After project approval, implementation and follow up
complete the EIA process. Monitoring, auditing and other tools
are used to ‘close the loop’ of impact prediction and condition
setting. They are important for several reasons: to identify the
impacts that occur; to check that these are within the levels
predicted and required by legislation; to determine that
mitigation measures are properly implemented and work
effectively; to ensure the environmental benefits expected are
being achieved; and to provide feedback to improve future
applications of the EIA process.

Timing
3 hours (not including training activity)

Important note to trainers

You should design your presentation with the needs

and background of participants in mind, and
concentrate on
those sections most relevant to your audience. The
session presentation timings are indicative only.
Topic 11
Time taken for the training activities can vary
enormously depending on the depth of treatment, the Implementation
existing skills and knowledge of participants and the and follow up
size of the group.

EIA Training Resource Manual u Second edition 2002 403

Training session outline

þ Information checklist
Obtain or develop the following materials, as appropriate:

q applicable requirements relating to implementation and follow

up of proposals;

q applicable procedures and guidelines for surveillance,

monitoring, auditing, etc.;

q local examples of the use and results of monitoring and

auditing;

q local examples of the use of environmental management

plans;

q local examples of post-project analysis, EIA performance

review or similar exercises;

q copies of any research or studies on the monitoring, impact

management and follow up activities;

q contact names and telephone numbers of people, agencies,

organizations and environmental information/data resource
centres able to provide assistance in relation to monitoring
and auditing; and

q other resources that may be available such as videos, journal

articles, lists of speakers, and case studies.

404 EIA Training Resource Manual u Second edition 2002

 Training session outline
Session outline

Welcome participants to the session by introducing yourself and

getting them to introduce themselves. Outline the overall coverage of
the session, its objectives, and why they are important.

Implementation and follow up are critically important but relatively neglected

stages of the EIA process. Surveillance, monitoring, auditing, evaluation and
other tools allow for ongoing assessment and review of the effects of the
proposal, following final approval. They are used to identify the impacts that
occur; check that these are within the levels predicted and required by
legislation; determine that mitigation measures are properly implemented and
work effectively; ensure the environmental benefits expected are being
achieved; and provide feedback to improve future applications of the EIA
process.

Outline the need for and purpose of EIA implementation and follow
up, emphasising their contribution to achieving good environmental
outcomes. Ask the participants if key objectives are relevant to EIA
practice locally.

Until recently, relatively little attention was paid to the actual impacts that
occurred during project construction and operation. Without appropriate
implementation and follow up to decision-making, EIA becomes a paper
exercise to secure an approval, rather than a practical exercise to achieve
environmental benefits (see Topic 7 – Mitigation and impact management). The
purpose of EIA implementation and follow up is to ensure that the conditions
attached to project approval are carried out and function effectively, and to
gain information that can be used to improve EIA practice in the future.

By itself, this process cannot turn around an environmentally unsound

project. However, it is critical to maximise the returns from the preparation of
the EIA report and its consideration in decision-making. EIA implementation
and follow up allow the measures and conditions attached to project approval
to be fine tuned in the light of new information. When used systematically,
they facilitate impact management, build continuity into the EIA process and
help to optimise environmental benefits at each stage of project development.

Topic 11

Implementation
and follow up

EIA Training Resource Manual u Second edition 2002 405

Training session outline

Key objectives of EIA implementation and follow up are to:

• confirm that the conditions of project approval are implemented
1 satisfactorily;
• verify that impacts are within predicted or permitted limits;
• take action to manage unanticipated impacts or other unforeseen
changes;
• ensure that environmental benefits are maximised through good
practice; and
• learn from experience in order to improve EIA process and practice.

Identify the components of EIA implementation and follow up, and

define key terms. Ask the participants to indicate which ones are
used in the EIA system locally, noting similarities and differences in
terminology.

The main components and tools of EIA implementation and follow up

include:
• surveillance and supervision – to oversee adherence to and
2
implementation of the terms and conditions of project approval;
• effects or impact monitoring – to measure the environmental changes
that can be attributed to project construction and/or operation and
check the effectiveness of mitigation measures;
• compliance monitoring – to ensure that applicable regulatory standards
and requirements are being met, e.g. for waste discharge and pollutant
emissions;
• environmental auditing – to verify the implementation of terms and
conditions, the accuracy of the EIA predictions, the effectiveness of
mitigation measures, and the compliance with regulatory requirements
and standards;
• ex-post evaluation – to review the effectiveness and performance of the
EIA process as applied to a specific project; and
• post-project analysis – to evaluate the overall results of project
development and to draw lessons for the future.

These components are variously defined and delineated in the institutional

arrangements and procedures established for this purpose by different
countries. However, their generic functions are reasonably well understood.
Key terms are described in the accompanying box, and reference is made to the
different types of monitoring, auditing and evaluation that may be undertaken
as part of EIA implementation and follow up. The usage of these tools will

406 EIA Training Resource Manual u Second edition 2002

 vary, depending on terms of project approval and circumstances (as discussed

Training session outline

later).
A conceptual distinction can be drawn between the respective aims of impact
management and review and feedback of experience. In practice, however,
these control and learning functions are not clearly separable. Rather they
form part of a continuum of implementation and follow up activities, which
are concerned with optimising environmental protection through good
practice at all stages of project development. This process, when integrated
with other environmental management and review tools, can be extended over
the whole life cycle of the project.

Box 1: Terminology of EIA implementation and follow up

2 11–1
Implementation and follow up are the terms used here to refer to all EIA related
activities that take place after an approval decision is made. The main functions
include:

Surveillance and supervision

Surveillance of the implementation of EIA terms and conditions can be undertaken
by regular or periodic site inspections to check on compliance, observe progress
and discuss issues. Supervision implies a more intensive direction of the
environmental performance of on-site activities, ensuring they are carried out in
accordance with the environmental management plan and/or contract
specifications.

Monitoring
Monitoring refers to the collection of data through a series of repetitive
measurements of environmental parameters (or, more generally, to a process of
systematic observation). The main types of EIA monitoring activities are:
• Baseline monitoring – the measurement of environmental parameters during
a pre-project period for the purpose of determining the range of variation of
the system and establishing reference points against which changes can be
measured.
• Effects monitoring – the measurement of environmental parameters during
project construction and implementation to detect changes which are
attributable to the project.
• Compliance monitoring – the periodic sampling or continuous measurement
of environmental parameters to ensure that regulatory requirements and
standards are being met.

Auditing
Auditing is a term borrowed from accounting to describe a systematic process of
Topic 11
examining, documenting and verifying that EIA procedures and outcomes
correspond to objectives and requirements. This process can be undertaken during Implementation
and follow up

EIA Training Resource Manual u Second edition 2002 407

Training session outline

and/or after project construction, and draws upon surveillance reports and
monitoring data. The main types of EIA related audits are:
• Implementation audits – to verify that EIA implementation met the
conditions of project approval.
• Impact audits – to determine the impact of the project and the accuracy of EIA
predictions.
• Compliance audits – to verify that project impacts complied with
environmental standards and regulatory requirements.
• Effectiveness or policy audits – to check the feasibility of mitigation
measures and the consistency of EIA practice.

Evaluation
Ex-post evaluation involves a policy-oriented review of the effectiveness and
performance of the EIA process. It is concerned with the overall ‘balance sheet’ of
an EIA, looking at what it achieved, which aspects were influential, and how the
process could be improved. The guiding concepts are:
• Effectiveness – the extent to which the EIA process has achieved its
purpose(s). Depending on how these are defined, an effectiveness review can
be conducted against the terms of reference, the information provided to
decision-makers or principles and criteria of EIA good practice (see Topic 1 –
Introduction and Overview of EIA).

• Performance – the success of the EIA process as measured by its outcomes and
results, e.g. the environmental benefits achieved or the effectiveness of
mitigation in avoiding or reducing impacts. Surveillance, monitoring and
auditing data are necessary for this purpose.

Post project analysis

Usually, a post-project analysis is undertaken once the project has been constructed
and is about to enter the operational phase. The term implies a focus on project-
specific EIA experience, e.g. in relation to dams, highways, waste disposal sites or
power generation. In this context, post-project analysis can include aspects of
effectiveness and performance review, using impact and mitigation data from
surveillance, monitoring and auditing.

Sources: Au and Sanvicens (1997) and Sadler (1988, 1998).

408 EIA Training Resource Manual u Second edition 2002

 Implementation
Topic 11

and follow up
Training session outline

409
Second edition 2002
Figure 1:The role and position of monitoring and management in EIA
Screening
Strategic Impact
Proposal and Decision Implementation
Planning assessment
Scoping

u
terms and conditions
of approval EIA audit and
post project

EIA Training Resource Manual

analysis
Monitoring
and impact
existing Baseline Surveillance/compliance checking Impact management
management plan for
data monitoring Design reassessment
implementation
and operation Baseline effect/compliance monitoring
Proactive activity monitoring/assessment
Ongoing
auditing

Adapted from Sadler (1988)

Information to an EMS
(such as ISO 14000)
Training session outline

Briefly relate EIA implementation and follow up to the other stages of

the EIA process and to the larger range of tools used in
environmental management and review. Ask participants to identify
which of these tools are used or relevant locally.

The role and contribution of EIA implementation and follow up are shown in
Figure 1 above. It illustrates:
• the relationship of EIA implementation and follow up to other stages of
the EIA process;
• the stages at which monitoring, auditing and evaluation are typically
undertaken; and
• the results and benefits that can be gained from their use.
The figure also illustrates the importance of early identification of follow up
requirements and measures, beginning at the stage of screening and scoping,
and adding to them as new information becomes available. Increasingly, the
preparation of an environmental management plan (EMP) provides the
blueprint for carrying out EIA implementation and follow up (see Topic 7 –
Mitigation and impact management). An EMP should include a schedule of
actions for this purpose, identify protocols for impact management in the
event of unforeseen events and specify the arrangements for the use of
surveillance, monitoring, auditing and other procedures.

EIA implementation and follow up can occur throughout project construction

and continue into the operational phase, becoming part of a larger process of
environmental management and performance review. The tools for this
purpose have developed rapidly. In particular, environmental management
systems (EMS) are now widely used by industry and business to manage the
impact of their activities on the environment. The ISO 14000 series provides a
framework of EMS principles, guidance and procedure, including
environmental auditing, performance review and life cycle assessment or
analysis. In the box below, these are grouped according to their primary use
and purpose.

Some of these tools are still under development, and their use and even
terminology varies. Certain aspects of the ISO 14000 series have yet to be
finalised. Already, however, there is an increasing recognition of the benefits
to be gained by linking EIA preparation and implementation to EMS design
and development; for example, initially through the transfer of information
and subsequently through the use of standardised procedures. Looking
ahead, EIA and EMS can be combined with other tools to take an integrated
approach to the total environmental impact of the project cycle, along the lines
indicated in Box 2.

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 Training session outline
Box 2: Tool box for environmental management and performance review

3&4 Purpose Examples of available tools

Internalising the environment in SEA, technology assessment, comparative risk

policy and planning assessment

Planning and designing EIA, SIA, risk assessment, environmental

environmentally sound projects benefit cost assessment

Environmental management of EMS (ISO 14000 series), total quality

the impacts of an operating environmental management (TQEM),
facility or business enterprise industrial codes of practice

Eco-design of processes and Environmental design, life cycle assessment,

products cleaner production

Monitoring, audit, and evaluation Effects and compliance monitoring, site,

of performance energy, waste, health and safety audits,
benchmarking performance

Explore with the group guiding principles and elements of approach

to EIA implementation and follow up. Ask participants whether and
how these might be applicable locally, noting the arrangements
made by different countries for this phase of the EIA process.

Guiding principles for carrying out the process of EIA implementation and
follow up include the following:
5 • the project should be carried out in accordance with conditions of
approval and the commitments made in the EIA report/EMP;
• surveillance and inspection should be a routine elements for this
purpose;
• the scope of other follow up activities should be commensurate with the
significance of the potential impacts; and
• monitoring, auditing and evaluation should be undertaken when
– potential impacts are likely to be significant,
– mitigation measures are untried or their outcome is uncertain,
and/or
– new aspects of EIA process and practice have been introduced.

A comprehensive approach to EIA implementation and follow up would

include many or all of the following steps and elements: Topic 11
• inspect and check the implementation of terms and conditions of project
Implementation
approval;
and follow up

EIA Training Resource Manual u Second edition 2002 411

Training session outline

• review the environmental implications of any changes that are required;

• monitor the actual effects of project activities on the environment and the
community;
• verify compliance with regulatory requirements and applicable
standards or criteria;
• take action to reduce or rectify any unanticipated adverse impacts;
• adjust the EMP, project specifications and related schedules as
necessary;
• audit the accuracy of the EIA predictions;
• evaluate the effectiveness of the mitigation measures; and
• provide feedback to improve EIA process and practice in the future.

The elements of approach to EIA implementation and follow up differ from

country to country. A variety of arrangements, as well as instruments, are
used. In some EIA systems, provision for monitoring and other follow up
activities is made in legislation, although it may apply only to certain project
categories or take place under the permitting and licensing processes of
regulatory agencies. In other cases, EIA follow up is a discretionary process,
which is carried out on a project-by-project basis by administrative,
contractual or informal means.

Review the aspects and issues that need to be considered in

designing and carrying out an EIA implementation and follow up
programme. Discuss how to determine the scope and components of
such a programme and ask participants to relate local experiences
in this area.

EIA implementation and follow up can be time consuming and expensive,

and not all projects warrant full attention. A disciplined approach should be
taken to planning this phase of the EIA process. Surveillance to oversee EIA
implementation and ensure compliance with conditions of approval and
regulatory standards is usually the bare minimum requirement. Other follow
up activities should be determined on the basis of the needs of environmental
management and the potential pay off for improving EIA practice in the
future.

The scope of follow up should be determined early in the EIA process. A

decision should be made as part of the screening and scoping process, when
requirements are established for baseline studies and monitoring. In part,
these decisions determine what can be done in EIA follow up, for example by
establishing the information that will be available for effects monitoring and
audit. Later, the scope of the EIA follow up programme can be refocused as
more detailed information on potential impacts becomes available.

412 EIA Training Resource Manual u Second edition 2002

 Key criteria for determining the need for and scope of EIA implementation and

Training session outline

follow up include:
• the degree of confidence or uncertainty attached to impact predictions;
• the level of risk and damage if unanticipated impacts occur;
• the significance of losses if controls are not properly implemented; and
• the opportunity to gain information that will add value to EIA practice.

Aspects and issues that need to be considered when designing and carrying
out an EIA implementation and follow up programme include:
6 • What is required? – Identify the scope and components of the programme,
and, if necessary, provide a justification and prioritise follow up actions.
• Who will carry out the activities? – Indicate the roles and responsibilities of
key agencies and individuals, noting how these will be coordinated and
emphasising any research aspects that may have been added
subsequent to the project approval, EMP or other core documents.
• How will the programme be carried out? – Specify the resources, expertise
and arrangements necessary to give effect to EIA follow up and to report
the results.

Stress the importance of monitoring as a vital component of the EIA

process, and describe its relationship to implementation and follow
up in general, and impact management in particular. Ask
participants to identify the monitoring methods and arrangements
that are in place locally.

Monitoring is a cornerstone of EIA implementation and follow up. Other

components are dependent on the scope and type of monitoring information
that is provided. The primary aim of monitoring is to provide information that
will aid impact management, and, secondarily, to achieve a better
understanding of cause-effect relationships and to improve EIA prediction
and mitigation methods. Both the immediate and long-term benefits from
undertaking monitoring as part of EIA are widely recognised, although not
always realised.

Monitoring is used to:

7 • establish baseline trends and conditions;

• measure the impacts that occur during project construction and
operation;
• check their compliance with agreed conditions and standards;
• facilitate impact management, e.g. by warning of unanticipated impacts;
and Topic 11
• determine the accuracy of impact predictions and the effectiveness of
Implementation
mitigation measures.
and follow up

EIA Training Resource Manual u Second edition 2002 413

Training session outline

A sound baseline is a critical reference point for the conduct of effects

monitoring. In turn, effects monitoring establishes the basis for corrective
action when actual impacts are unanticipated or worse than predicted.
Compliance monitoring, carried out through repetitive or periodic
measurement, also can be used for this purpose. This may suffice as a safety
net for certain projects, for example, where the mitigation measures are well
tried and known to be effective. However, compliance monitoring will trigger
impact management only if regulatory standards or specified conditions are
exceeded and, on its own, may be insufficient for large-scale, complex projects.

By themselves, compliance and effects monitoring permit only reactive impact

management, since they detect violations or adverse changes after the fact. In
this context, it is important to tie the results of both types of monitoring to pre-
determined actions (or emergency responses), which are triggered on a
threshold basis. A more proactive, adaptive approach to impact management
can be instituted by combining compliance or effects monitoring with
supervision or regular inspection of site clearance, construction and
mitigation activities. The use of the precautionary principle can facilitate early
warning of emerging problems.

Emphasise the need for monitoring programmes to be carefully

targeted and cost-effective. Ask the participants if there is any
experience locally on this aspect of EIA follow up, and what
resources might be available.

The collection of monitoring data is expensive. It needs to be targeted at the

information necessary to manage the impacts that are significant or review the
aspects of EIA practice that are of particular importance. These aspects should
be identified as early as practicable in the EIA process to optimise the
contribution of monitoring data to EIA implementation and follow up.
Monitoring involves designing the programme, collecting and analysing the
data, establishing their linkage to impact management, auditing and other
components, and interpretation and reporting of data.

The following points need to be agreed as part of the EMP and conditions of
project approval:
8 • major impacts to be monitored;
• objectives of monitoring and data requirements;
• arrangements for the conduct of monitoring;
• use of the information to be collected;
• response to unanticipated or greater than predicted impacts; and
• measures for public reporting and involvement.

Monitoring requirements should focus on the significant impacts predicted in

the EIA report, taking account of:

414 EIA Training Resource Manual u Second edition 2002

 • the environmental values to be safeguarded;

Training session outline

• the magnitude of each potential impact;
• the risk or probability of each impact occurring;
• the pathways and boundaries of each impact; and
• the confidence in the prediction of each impact.

Monitoring programmes need to be constantly reviewed to make sure that

relevant information is being supplied, and to identify the time at which they
can be stopped.

Outline the basis for a scientifically credible monitoring programme.

Provide participants with general information about how data can be
collected and analysed, and draw attention to the role of
independent checks.

Each discipline has established methods for monitoring and data collection.
For example, the design of a programme to monitor the impact of a large-scale
project involving discharge of toxic waste or effluent into a water body may
encompass different methods to measure change in water quality, food chains,
fish reproduction, reduction in income from fisheries and its effect on the local
community. Generally, monitoring to detect chemical and physical changes is
more straightforward than for biological effects or ecological relationships.
Socio-economic impacts present a special challenge of measuring changes in
collective behaviour and response (see Topic 6 – Impact analysis).

The general approach to effects monitoring is to compare the pre- and post-
project situation, measuring relevant environmental impacts against baseline
conditions. A common issue in all situations is how to differentiate the change
attributable to a project from the variability that characterises all biophysical
or socio-economic systems. In the real world, as opposed to laboratory
experiments, cause-effect relationships are difficult to separate from the
interaction of other factors. Eliminating or correcting for these intervening
variables is the key to the design and conduct of a scientifically defensible
effects monitoring programme.

Typically, this problem is addressed by establishing impact and control

monitoring stations. The impact or treatment site is selected to be a receptor of
an emission, hazard, event or action from the project. An example would be a
water sampling station downstream from an effluent discharge point. The
control or reference site is located outside the impact zone, but chosen to be
representative of the variability experienced by the impact site. ‘With versus
without’ project comparisons then can be made to determine the change or
impact that is attributable to the project. Topic 11

Monitoring programmes result in time series data, which can be analysed by: Implementation
• assembling the data in tabular or graphic format; and follow up
9

EIA Training Resource Manual u Second edition 2002 415

Training session outline

• testing for variations that are statistically valid;

• determining rates and directions of change; and
• checking these are within expected levels and comply with standards
(e.g. water quality).

Some relational changes, such as in chemical constituents in water, can be

presented graphically. Longitudinal studies based on numerical data or
photographic or descriptive records also provide relevant information on
changes and trends. The figure below is an example of monitoring data. It
depicts the variation in contaminant levels and their relation to seasonal
precipitation, including the effect of an extreme event (drought) on sulphate
concentration. Also shown are the independent checks made by the regulatory
agency on a proponent’s data.

Monitoring data needs to be interpreted and reported to a non-scientific

audience, including decision makers, the affected community and the general
public. This may be the responsibility of a regulatory body, monitoring team or
multi-stakeholder group, established specifically to bring a broad
understanding and a range of views to EIA implementation and follow up.
Where different types and methods of monitoring have been carried out, the
comparability and quality of the data sets may need to be addressed and
reported. Reports should be in plain language and to appropriate technical
standards (see also Topic 8 – EIA reporting).

EPA, (1995) ∆, ο regulator's independent checks of SO4 and EC respectively

Figure 1:Proponent long-term monitoring showing seasonal variations

2
Using a local example or Handout 11–2, discuss the elements and
steps in developing a credible and effective environmental
11-2 monitoring programme.

416 EIA Training Resource Manual u Second edition 2002

 Appropriate guidance should be sought when developing an environmental

Training session outline

monitoring programme. Typically, some or all of the following issues will be
addressed:
• representative impact and reference sites;
• methods for sampling and collection of data;
• independent checks for quality control and assurance of data;
• basis for statistical interpretation and inference of impacts;
• protocols for the conduct of environmental auditing; and
• mechanisms for reporting data and responding to issues that are raised.

Some elements of an effective environmental monitoring programme are listed

in Box 3. The following steps can help to implement these elements:
10 • define the scope and objectives of monitoring for each impact;
• identify the sites for observation, measurement and sampling;
• select the key indicators for direct measurement or observation;
• determine the level of accuracy required in the data;
• consider how the data will be analysed in relation to baseline and other
data;
• establish a system for recording, organising and reporting the data;
• specify thresholds of impact acceptability; and
• set requirements for management action if monitoring indicates these are
exceeded.

When adapting these to scale and circumstances, those responsible for

developing monitoring programmes should consider the value of simple
observation and reporting, particularly by locally affected parties. Increasing
attention is being given to public involvement in the EIA implementation and
follow up. For example, stakeholder or citizen monitoring committees have
been used in a number of cases. The terms of reference can be written into EIA
documentation and include building a long-term relationship with an affected
community or group of stakeholders when the project is complex and
controversial.

Topic 11

Implementation
and follow up

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Training session outline

Box 3: Effective environmental monitoring programmes have:

• a realistic sampling programme (temporal and spatial)

• sampling methods relevant to source and/or type of impact
• a targeted approach to data collection
• comparability of data with baseline and other relevant data
• quality control in measurement and analysis
• systematic record keeping and database organisation
• reporting requirements for internal and external checks
• provision for input from and response to third parties
• presentation of results to the public

2 11–3
Discuss how to implement a monitoring programme. If there is a local
case study available use this to explore the costs of monitoring and
discuss how these might be offset by the benefits that can be derived
from monitoring information. Where no detailed local costings are
available, use the materials in Handout 11–3 to discuss possible costs
of procedures.

A budget for the monitoring programme needs to be drawn up and the

resources and personnel necessary to carry them out specified. Normally, this
will be finalised as part of preparation of the EMP. Alternatively, this can be
undertaken as a separate exercise, as part of detailed project specifications or
incorporated into permitting, licensing or contracting. The latter instruments
have advantages in ensuring compliance and enforcement of monitoring and
other follow up requirements, but they are not in place in all EIA systems.

The costs of EIA related monitoring can vary greatly, depending on the project,
the location, the environment affected and the potential significance of the
impacts. Other things being equal, the greater the level of uncertainty about
potentially significant impacts, the higher the cost of monitoring to obtain
information that is relevant to impact management and improved
understanding. However, the costs can be offset by the benefits which
monitoring brings. These may include immediate savings gained by timely
action to correct unanticipated impacts.

Depending on the nature and severity of the impact, this might involve one or
more of the following measures:
11 • stopping or modifying the activity causing an excessive impact;
• imposing penalties or prosecution where conditions and standards are
breached; and

418 EIA Training Resource Manual u Second edition 2002

 • scaling up or adding mitigation measures (in situations where this is

Training session outline

possible).

Longer-term gains can also accrue from baseline and effects monitoring. For
example the data can be used to establish a reference basis for managing
environmental impacts throughout the life of the project. This information will
be particularly helpful to the design of an EMS to address the environmental
aspects and impacts of the operational phase of the project. Wherever
possible, the inputs from monitoring, auditing and other components of EIA
implementation and follow up should be integrated into this framework.

Now consider the role of auditing in EIA implementation and follow

up, noting its relationship to other types of environmental audit
undertaken as part of an EMS. Ask participants to discuss local
experience with EIA and EMS 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;
12 Topic 11
• test the accuracy of impact predictions;
Implementation
• check the effectiveness of mitigation measures; and
and follow up

EIA Training Resource Manual u Second edition 2002 419

Training session outline

• improve compliance and performance of EIA practice.

EMS audits include:

• site audits – to examine all aspects of environmental management of a
facility or operation;
13
• 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.

Describe the types of information that are gained from EIA auditing
and their use in improving the EIA process. Point out the importance
of a well-designed monitoring programme, noting the other options
for the conduct of audits when the necessary monitoring data is not
available.

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 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;
14
• late changes to project design and mitigation (thereby altering the basis
on which predictions are made); and

420 EIA Training Resource Manual u Second edition 2002

• long lead times before certain trends and impacts can be identified, for

Training session outline

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).

B ox 4: Environmental monitoring and audit of the Chek Lap Kok Airport,

Hong Kong SAR

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

Topic 11
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 Implementation
reasonably accurate (except for cumulative effects) but there were cases where the and follow up

EIA Training Resource Manual u Second edition 2002 421

Training session outline

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.

Source: Sanvicens 1995.

Introduce the concept of evaluation of EIA effectiveness and

performance. Ask participants whether there is any experience
locally with this type of review.

Ex-post evaluation of EIA effectiveness and performance can be undertaken at

a number of levels. In this topic, the emphasis is on a ‘before and after’ review
of a specific EIA process, focusing on what was achieved and which elements
of approach contributed to good environmental outcomes. This type of
evaluation can be undertaken as an integral component of EIA
implementation and follow up, for example to identify the results and lessons
of the experience and feed them back into policy action. However, examples of
this approach are limited, and fewer still are based on a systematic review of
surveillance, monitoring and auditing data.

Other evaluations of aspects of EIA effectiveness and performance that can

provide relevant information include:
• annual or periodic reports on the implementation and performance of
EIA systems, e.g. three year review of World Bank experience;
• national and comparative reviews of the quality of EIA reports, e.g. as
undertaken in Australia, Canada and the USA;
• reviews of the relationship of the EIA process and decision-making; and
• post-project analyses focusing on the results of EIA inputs and activities.

Despite recent progress, however, there is a lack of widely agreed frameworks

for conducting reviews of EIA effectiveness and performance in the above
areas. By contrast, in the EMS cycle, review and reporting are integral
procedures for improving environmental performance. In leading companies,
these are combined with monitoring, audit and other tools to address all
impacts of their operations. A review of EIA effectiveness and performance

422 EIA Training Resource Manual u Second edition 2002

can replicate this approach to document and disseminate the lessons of

Training session outline

experience and build the knowledge base on project-specific impacts.

Briefly summarise agency responsibilities for EIA implementation and

follow up activities, and note how these apply locally.

Typically, the responsibility for EIA implementation and follow up activities

will be divided among different agencies and individuals. For example:
• the competent authority usually oversees the implementation of the terms
and conditions of approval;
• the proponent (often through sub-contractors) normally carries out the
scheduled activities, such as site clearance and preparation,
construction and environmental management;
• the environmental or regulatory agency usually inspects mitigation
measures, reviews monitoring data and verifies compliance and
effectiveness; and
• the public can have a formal role in environmental monitoring and audit,
e.g. where a stakeholder or community review committee is in place. In
other cases, there may be provision for public disclosure of monitoring
and audit reports and opportunities for informal review and comment.

Include a training activity to reinforce the topic (if desired).

Conclude by summarising the presentation, emphasising the key

aspects of the topic that apply locally.

Topic 11

Implementation
and follow up

EIA Training Resource Manual u Second edition 2002 423

References and further reading

Reference list

The following references have been quoted directly, adapted or used as a

primary source for major parts of this topic.

Au E and Sanvicens G (1997) EIA Follow up and Monitoring in Report of the EIA
Process Strengthening Workshop (pp. 91-107). Environment Protection Agency,
Canberra.

Environment Protection Agency (1995). Best Practice in Environmental Management in

Mining. Environmental Monitoring and Performance. Environment Protection Agency,
Canberra.

Industry and Environment (1995) 18: 2&3. Special issue on environmental

management tools.

Sadler B (1998) Ex Post Evaluation of the Effectiveness of Environmental

Assessment (pp.30-40). In Porter A and Fittipaldi J (eds) Environmental Methods
Review: Retooling Impact Assessment for the New Century. The Press Club, Fargo, USA.

Sanvicens G (1995) Environmental Monitoring and Audit of the Airport Core Programme
Projects in Hong Kong. Environmental Protection Department, Hong Kong.

Scott Wilson Ltd. (1996) Environmental Impact Assessment: Issues, Trends and Practice.
Environment and Economics Unit, UNEP, Nairobi.

UNECE (1990) Post Project Analysis in Environmental Impact Assessment. United

Nations, New York.

Further reading

Arts J and Noteboom S (1999) Environmental Impact Assessment Monitoring and

Auditing. In Hillary R and Jolly A (eds) (2000) The CBI Environmental Management
Handbook. Earthscan, London, UK.

Petts J (ed) Handbook of Environmental Impact Assessment. Vol. 2 (pp.229-251).

Blackwell Science Ltd, Oxford, UK.

World Bank (1995) Environmental Auditing. Update. Environmental Assessment

Sourcebook. World Bank, Washington, DC.

World Bank (1997) Environmental Performance Monitoring and Supervision.

Update. Environmental Assessment Sourcebook. World Bank, Washington, DC.

424 EIA Training Resource Manual u Second edition 2002

Training activities

Training activities
Training activities will be more instructive if they are framed around a local proposal.
Consider inviting prospective course participants to make a presentation if they have
expertise in this area of EIA.

Discussion themes
11-1 Why is EIA implementation and follow up important? Do all projects
need to be monitored during construction and after they have begun
operation?
11-2 Who should be responsible for implementation and follow up
activities?
11-3 How can decision-making agencies best link conditions of approval to
the implementation and follow up of a proposal?
• What steps and measures are necessary to ensure there is an
appropriate response to unanticipated impacts and unforeseen events?
• Is there a role for the public in these stages of the EIA process?

11-6 How might an EIA audit be conducted when there is no or insufficient

monitoring data?

Speaker themes
11–1 Invite a speaker with experience in monitoring local projects to outline
how the monitoring plans were developed, how often they have been
adopted and how successful they have been in practice.
11–2 Invite an expert speaker with specific monitoring expertise of relevance
to the participants to provide detailed coverage of the planning,
implementation and review of monitoring programmes.
11–3 Invite a speaker with experience in the audit of local EIAs to address
the participants, present the findings of the audit and make suggestions
for the future improvement of EIAs in the area.

Topic 11

Implementation
and follow up

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Training activities

Group Activity 11–1: Monitoring, implementing and

auditing

Title: Preparing environmental monitoring programmes

Aim: To use an EIA report as the basis for planning an

environmental monitoring programme.

Group size: Four or five people, reporting to whole group at end of

session.

Duration: Half-day to one day depending on the level of detail

required.

Resources required:

o An EIA report for each group.

o Local case study for reference (or use Handout 11–3 if none is
available locally).

o Support references such as the World Bank Environmental

Assessment Sourcebook to provide the participants with technical
and social information about the monitoring of different impacts
(see reading list for details). Also search for something less
technical to be representative of local monitoring.

Description of activity:

Using the EIA report each group is to:

o Plan an environmental monitoring programme noting:

– the scope of the monitoring;
– the objectives of monitoring the impacts;
– how the information can be collected;
– the boundaries of the proposed measurement and
observation;
– key indicators to be used for measurement or observation;
– how the data can be analysed;
– the level of accuracy required in the data;
– how the plan can be reviewed;
– what action is to be taken in the case of problems; and
– who is responsible for monitoring, paying, checking (auditing).

o Present the results to the whole group.

o Finish with a discussion of the adequacy of the EIA report for

supporting the production of monitoring programmes.

o Discuss how EIA reports could be improved in this regard.

426 EIA Training Resource Manual u Second edition 2002

Group Activity 11–2: Monitoring, implementing and

Training activities
auditing

Title: Reviewing an environmental monitoring programme

Aim: To critically evaluate the adequacy of a monitoring

programme.

Group size: Four or five people

Duration: Half-day

Resources required :

o A copy of an environmental monitoring programme for each group

member.

o The EIA report associated with the programme.

o Support references such as the World Bank Environmental

Assessment Sourcebook to provide the participants with technical
and social information about the monitoring of different impacts
(see Reading list in Section A of the manual for details).

Description of activity:

o The adequacy of the monitoring programme is to be reviewed

against the impacts (and their severity) highlighted in the EIA
report.

o Suggestions should be made about how the programme (timing,

completeness, allocation of responsibility etc) can be improved.

o The findings of the small groups should be reported to the whole

group for final discussion.

Topic 11

Implementation
and follow up

EIA Training Resource Manual u Second edition 2002 427

Support materials

Aims of EIA implementation and follow up are to:

• carry out conditions of approval
• ensure they work effectively
1
• verify impacts are as predicted or permitted
• take action to manage unforeseen changes
• optimise environmental benefits
• improve EIA practice in the future.

Key components of EIA implementation and follow up include:

• surveillance and supervision
2
• effects or impact monitoring
• compliance monitoring
• environmental auditing
• evaluation of EIA effectiveness and performance
• post-project analysis

Tool box for environmental management and performance review

• Internalising the environment in policy and planning – use SEA,
3 technology assessment, comparative risk assessment
• Planning and designing environmentally sound projects – use EIA, SIA,
risk assessment, environmental benefit cost assessment
• Environmental management of the impacts of an operating facility or
business enterprise – use EMS (ISO 14000 series), total quality
environmental management (TQEM), industrial codes of practice

Tool box for environmental management and performance review (cont.)

• Eco-design of processes and products – use environmental design, life
cycle assessment, cleaner production
• Monitoring, audit, and evaluation of performance – use effects and
4
compliance monitoring, site, energy, waste, health and safety audits,
benchmarking, performance review, environmental auditing

Guiding principles of EIA implementation and follow up:

• carry out conditions of approval
• undertake routine surveillance and inspection
5
• other activities should be commensurate with significance
• monitoring and auditing should be undertaken when
– potential impacts are potentially significant
– mitigation measures are untried/ outcomes uncertain
– new aspects of EIA introduced

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 Aspects to consider in design of EIA implementation and follow up:
what is required?
– identify the scope and components
6
who will carry out the activities?
– specify roles & responsibilities
how will these be implemented?
– allocate resources, define procedures & arrangements

Monitoring is used to:

establish baseline conditions
7 measure actual impacts and trends
verify they comply with agreed conditions
facilitate impact management
determine the accuracy of impact prediction
review the effectiveness of mitigation measures

Monitoring requirements in the EIA/EMP:

impacts to be monitored
8 objectives and data requirements
arrangements for conduct of monitoring
use of the information collected
response to unanticipated impacts
measures for public reporting and involvement

For scientifically credible monitoring:

use methods of a relevant discipline
9 establish impact and reference sites
result in time series data which can be analysed by
– assembling the data in tabular or graphic format
– testing for variations that are statistically valid
– determining rates and directions of change

Topic 11

Implementation
and follow up

EIA Training Resource Manual u Second edition 2002 429

Support materials

Steps to develop an effective monitoring programme:

define the scope and objectives (for each impact)
10 identify the boundaries and select sites
choose the key indicators
determine the level of accuracy required in the data
consider how the data will be analysed
establish a data and reporting system
specify thresholds of impact acceptability
set requirements for action on exceedences

Actions to address excessive impacts or unanticipated changes:

stop or modify the causal activity
11 impose penalties if legal standards are breached
add or scale up mitigation measures (if feasible)

EIA audits are used to:

identify impacts and results
verify conditions of approval are being met
12 test the accuracy of impact predictions
check the effectiveness of mitigation measures
improve compliance and performance

EMS audits include:

site audits
compliance audits
13
sector & issue audits, e.g.
– waste
– energy
– health and safety
– supply chains

Difficulties commonly experienced in EIA Audits

14 • limited baseline information
• qualitative and non auditable predictions
• changes to project design and mitigation
• long lead times for some types of impact

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