Environmental management plans describe how an action might impact on the natural environment in which it occurs and set out clear commitments from the person taking the action on how those impacts will be avoided, minimised and managed so that they are environmentally acceptable.
General principles for the preparation of an environmental management plan
Key principles
- An environmental management plan should:
- be balanced, objective and concise
- state any limitations that apply, or should apply, to the use of the information in the environmental management plan
- identify any matter in relation to which there is a significant lack of relevant information or a significant degree of uncertainty
- include adaptive management strategies for managing uncertainty
- be written in a way that is easily understood by other parties
- clearly present how conclusions about risks have been reached
- ensure that the person taking the action takes full responsibility for the content and commitments contained in the plan.
Including commitments in management plans
- All commitments must be specific and auditable with measurable outcomes and clear timeframes.
- To ensure readability, write clearly and avoid long sentences with complex clauses.
- Always use the terms ‘will’ and ‘must’, rather than ‘should’ or ‘may’ when committing to carry out management actions.
- Avoid use of ambiguous terminology such as ‘where possible’, ‘as required’, ‘to the greatest extent possible’. If it is necessary to include ambiguous terminology, it should be explained and examples given.
- Clearly explain any technical terms or acronyms used, and/or define them in a glossary
Cross-referencing
Where the plan refers to material in other documents, it should include cross-references that are clear, complete and that specify the document version and date. Use tables, diagrams and maps where their inclusion would provide a better understanding and implementation of the management plan. Link all tables, diagrams and maps into the text through cross-referencing.
Timing the submission of an environmental management plan
Under the EPBC Act an approval is required for any proposed action which is likely to have a significant impact on a matter protected under national environment law. Proposed actions which require an approval are subject to an environmental impact assessment process. It is best to submit environmental management plans early in the assessment process. This enables the plan to be fully considered and, if the action is approved, can result in simpler conditions of approval.
Once a proposed action is approved, conditions may be attached to that approval requiring that an environmental management plan be submitted to the Minister for approval before the action begins. Reviewing and approving the plans takes time and sometimes modifications are required before the Minister or their delegate will approve them.
Accordingly, environmental management plans should be submitted for approval at least three months before approval is needed. Alternative timeframes should be discussed with Departmental officers to ensure that expectations are met. This approach will reduce the likelihood that activities are delayed while waiting for the plan to be approved.
Cost recovery under the EPBC Act
Cost recovery for environmental impact assessments and some strategic assessments under the EPBC Act commenced on 1 October 2014. Cost recovery is the charging of a fee to cover the cost of specific services provided by the Australian Government for work that benefits particular groups or individuals. The introduction of cost recovery for environmental assessments under the EPBC Act means that each person proposing to take an action that will have or is likely to have a significant impact on a matter of national environmental significance will pay for the services required to assess their application. Fees for assessment activities apply to any action referred under Part 7 of the EPBC Act on or after 14 May 2014, where the actual assessment work is undertaken on or after 1 October 2014. If an action is referred on or after 1 October 2014, then cost recovery will apply to both the referral and any assessment activities undertaken. Cost recovery may also apply where a person wishes to undertake a strategic assessment under Part 10 of the EPBC Act from 1 October 2014.
Content of the Environmental Management Plan
Cover page and declaration of accuracy
Cover page detailing:
- EPBC number
- project name
- proponent /approval holder and ACN or ABN
- the proposed/approved action
- location of the action
- date of preparation of the environmental management plan
- person accepting responsibility for the environmental management plan – signed declaration (see below).
Document version control
The document version control should be a simple system that ensures that details of all key changes to the document over time are properly recorded. Identified changes should include details of timings, persons responsible and reasons for changes.
Table of contents
Table of contents page detailing:
- all section headings and page numbers
- all figures, tables, plans and maps (should be numbered)
- all appendices (with meaningful titles, including for sub-appendices if any). If the appendices contain a collation of data, include summary of the contents.
Executive summary or introduction
The executive summary should note the key elements of the project, the purpose of the document, the main potential impacts and the primary strategies planned to address these impacts.
Conditions of approval reference table
When an environmental management plan is prepared after the project has been approved under the EPBC Act, the management plan should include a table detailing the information noted below:
- The EPBC Act approval condition requirements the plan is intended to address. These are best presented broken down into each of the individual actions that the conditions require.
- The section and page numbers which address the approval conditions.
- A summary of the key commitments relating to each of the approval conditions.
Project description
The environmental management plan should provide a description of the project as this provides context for the plan. The location of all project actions should be described and a map showing their location provided. Basic information on the environment at these locations should also be included as this helps provide them environmental context to which the environmental management plan applies.
The plan should include a description of the activities that will be undertaken as part of the project including project details relevant to any approval conditions and with potential impacts on matters protected under the EPBC Act. The plan should distinguish between construction and operational activities, if relevant. A schedule of intended commencement and completion dates should be provided. Projects undertaken in stages should identify each stage in the schedule. Contingency schedules can also be included along with examples of events that could result in the use of the contingency schedules.
Objectives
The environmental outcomes of the plan should be defined. These should be tailored to the environmental issues outlined in the plan.
Environmental management roles and responsibilities
Once an action is approved, the approval holder is responsible for complying with the conditions of approval, including the commitments made in environmental management plans. The plan should define the roles and responsibilities of personnel in charge of the environmental management of the project. The roles and responsibilities of each relevant position should be documented, including the responsibilities of subcontractors. The names of the responsible personnel do not need to be included. Identification of the position titles, roles and responsibilities is sufficient. If the roles and responsibilities are expected to change over time the long term variations should also be documented.
Reporting
An environmental management plan will usually require reporting arrangements for two purposes. Reporting arrangements assist with effective implementation and with external reporting. External reports may include reports on environmental incidences to the regulator, reports to stakeholders, reports to inform reviews of the plan and reports to meet the reporting requirements of the conditions of approval.
The description of reporting requirements should include:
- a list of required reports including where appropriate monitoring, environmental incidents, non-compliance, corrective action and auditing
- a description of the standard report content
- the schedule or triggers for preparing a report
- who the report is provided to
- document control procedures
- Reporting commitments should also be consistent with any reporting to the Department required by the conditions of approval.
Environmental training
All people involved with the project should receive relevant environmental training to ensure they understand their responsibilities when implementing the environmental management plan. People to be trained include those at the site/s of all project activities and operations, including contractors, subcontractors and visitors. The training should be tailored to the role of the individual in the project.
The environmental management plan should describe the training to be implemented and could include:
- site inductions
- identification of key points of environmental value and any relevant matters of national environmental significance
- understanding the requirements of the environmental management plan and the individual’s role.
- environmental incident emergency response procedures
- site environmental controls
- an outline of the potential consequences of not meeting their environmental responsibilities.
Records of all training conducted should be maintained and include:
- the person receiving the training
- the date the training was received
- the name of the person conducting the training
- a summary of the training.
Emergency contacts and procedures
The environmental management plan should identify the key emergency contacts responsible for managing environmental emergencies associated with the project and their contact details. These personnel should have the power to stop and direct works so that they can manage emergencies effectively. In addition, the plan should establish procedures for managing environmental emergencies and ensure that those procedures are implemented and maintained.
Potential environmental impacts and risks
Threats to matters protected under the EPBC Act
The environmental management plan should summarise all the identified threats to matters protected under Part 3 of the EPBC Act in the management plan. The matters protected by the EPBC Act include:
- the nine matters of national environmental significance (listed in Appendix A)
- the environment in general (for actions by Commonwealth agencies or actions on Commonwealth land) or the environment on Commonwealth land (for actions outside Commonwealth land).
Potential impacts
The potential impacts section of the plan should focus on identifying, locating and quantifying the potential impacts (direct and indirect) of the project on the matters protected by the EPBC Act. It should discuss:
- the relevant impacts of the project
- the nature and extent of the potential short-term and long-term effects
- any uncertainties regarding the predicted impacts.
Risk assessment
Once the potential impacts of the proposal are clearly identified a risk assessment should be undertaken for each potential impact. This means that the likelihood and consequences of each potential impact need to be estimated
The function of the risk assessment is not to repeat or supersede the original assessment of a project or its conditions of approval. Rather it is to ensure that these risks are effectively translated into actual mitigation and management actions. Impacts with higher risk ratings usually require more management actions and controls. This minimises the likelihood of the risk occurring and reduces the consequences to acceptable levels.
Environmental management measures
The environmental management plan should clearly state how the potential impacts of the proposal will be managed and this information usually forms the bulk of the content of the plan. For each potential impact the plan should address:
- environmental management activities, controls and performance targets
- environmental management maps and diagrams
- monitoring programs with trigger values for corrective actions
- corrective actions and non-compliance reporting
- environmental schedules.
Environmental management activities, controls and performance targets
The environmental management plan should describe all the environmental management activities and control measures that will be implemented to avoid or minimise environmental impacts. The description of each measure should also specify the timeframes for implementation and the performance targets or outcomes to be achieved. The timing of measures is often best presented in a timetable. Performance targets and outcomes should be quantative and auditable.
Environmental management maps and diagrams
Environmental management maps and diagrams are useful visual tools that aid in environmental management activities. Maps can provide useful spatial information about areas that require environmental management.
For example, a map could be used to show:
- environmentally sensitive areas on or near a project site
- vegetation that requires protection
- buffer zones or ‘no-go zones’
- monitoring locations.
Environmental monitoring
The environmental management plan should specify how the effectiveness of environmental management measures will be monitored. It should include the methodology, frequency and duration of monitoring activities. It should also include trigger values or conditions under which corrective actions are taken. The plan should also specify if, and when, follow up action is required and how monitoring records will be maintained.
Corrective actions
The environmental management plan should include procedures for addressing:
- monitoring results which exceed the trigger values for corrective action
- potential corrective actions
- reporting non-compliance with approval conditions to the relevant authority
- environmental incidents and emergencies.
The plan should also identify who is responsible for implementing the above procedures. Auditable systems should be developed for recording the implementation of these procedures and their outcomes.
Audit and review
Environmental auditing
The environmental management plan should include the schedule or triggers for auditing the implementation and effectiveness of the plan. It should address both internal and external audit requirements including who is responsible for undertaking the audits and reporting the results.
Environmental management plan review
The environmental management plan should specify the schedule or triggers for reviews of the plan. A review should assess whether the plan is achieving its objectives and the requirements of any relevant approval conditions. A review should take into account environmental monitoring records, corrective actions and the results of any audits. The plan should also identify who will be responsible for undertaking the review. During the review process, any reasons for varying the environmental management plan should be documented.
Review of an environmental management plan would typically be undertaken:
- following significant environmental incidents
- when there is a need to improve performance in an area of environmental impact
- periodically for actions undertaken over long timeframes such as one, two or five years.