7.3.1.2.

All low priority environmental impacts shall be listed in the Report. Although no further analysis of them is necessary at this point, the priority evaluation of these impacts should be reviewed throughout the life of the project.

7.3.2.1.

Where Procedure EMP04 Impact Screening and Scoping has shown that there is a potential for adverse environmental impacts of medium priority or high priority, then appropriate actions to eliminate, reduce and/or monitor the associated environmental aspects, shall be formulated. The categorisation of impacts into medium priority and high priority will assist Delivery Teams to make appropriate management decisions for addressing the impacts.

7.3.2.3.

7.3.2.4.

The cause (“source”) of the environmental risk follows a route (“pathway”) to the ecosystem (“receptor”) which could come into contact with the environmentally damaging/polluting substance. A “pollution linkage” occurs when all three components of the Model are in place. Therefore, elimination of any of these three components will break the pollution linkage and mitigate or eliminate the environmental risk. Attention should be placed initially at eliminating or reducing the environmental impact at source before examining ways of removing/protecting the pathway or receptor. Form Environmental Feature Matrix , will help with this. Actions identified at this stage shall be recorded in the Environmental Impact Management Report, Environmental Case Report, Objectives and Targets register and Operational Controls Log as appropriate.

7.3.2.6.

Note - environmental management has not failed in any way if environmental impacts cannot be removed or mitigated against. Providing there is an operational case that outweighs the environmental issues, the project can still proceed provided that the POEMS assessment has been conducted and provides evidence that the environmental impacts have been considered. This will demonstrate that practical and reasonable measures have been put in place to eliminate all but the unavoidable adverse environmental impacts.  It is here where there may be benefits from managing ‘Normal’ impacts separately to the abnormal and emergency events that may be experienced In-Service. Care must be taken to identify aspects that can be controlled by procurement Delivery Teams, and full recording and justification of decisions must be carefully described.

7.3.3.1.

Where an impact is unique to each life cycle stage the assessment of that impact can be straightforward and in some cases may even be trivial. However, in some projects the importance of individual impacts may only become evident when the cumulative effects are considered. In most cases this is taken care of by the frequency and duration element that shall be entered in Form Environmental Feature Matrix.

7.3.7.2.

Before authorisation, the environmental delegation holder shall ensure the satisfactory resolution of any deficiencies or observations raised through the project’s Environmental Committee or by parties engaged by the Project to undertake independent audits or assessments.

7.4.0.1.

The Delivery Team Leader is responsible for ensuring adequate resources are dedicated to the management of safety and environmental protection within their area of responsibility, and for facilitating appropriate arrangements to discharge responsibilities relating to this procedure in an efficient and effective manner.

7.6.1.1.

For complex or strategically important capabilities an initial EIM Report may be carried out as early as the Concept Stage prior to Outline Business Case approval. However, in most cases the EIM Report is likely to commence in the Assessment Stage and some may not be necessary until the Demonstration or even the Manufacturing Stage. 

7.9.1.1.

The key alignment opportunity in EMP06 shall be to ensure that opportunities for combining environmental and safety reporting are explored and where possible are achieved by the same action.

7.9.2.1.

The objectives for this procedure apply to all acquisition strategies.  It is MOD policy that the same standards are met, and that assurance that these standards have been met can be demonstrated for all projects.  In many cases EIM will be completed by contractors and/or equipment suppliers that have knowledge of the specific issues and areas.

7.9.3.1.

Outputs from this procedure for legacy systems should be neither over-engineered nor incomplete (the outputs from EMP02, EMP03 and EMP04 will help define the most appropriate extent and nature of the work required).  In all cases it will be important to ensure that all applicable legislative and other requirements have been identified to confirm that all appropriate mitigation measures have been identified and shared with the stakeholders or are now agreed and actioned.  Only in cases where a mid-life update or similar is planned would there be a need to look at possible elimination of impacts.  Thus it will be seen that for many legacy systems, with limited life, it will be appropriate to concentrate on disposal arrangements and impacts especially where there is no evidence of environmental incidents or accidents associated with the system.

7.9.4.1.

If this procedure is not completed, and reviewed (see Procedure EMP09 – Continuous Review), in a timely manner there will be an increase in risk that subsequent work will go ahead with unrecognised environmental liabilities. Any short comings in this could compromise Full Business Case procedures and approvals. In addition, short comings could also result in costly reworks, especially where opportunities to influence design decisions are missed.

7.9.5.1.

Statement of Need

Information about the need for the equipment or service and any alternatives that have been considered (the URD (User Requirement Document) and SRD (System Requirement Document) should form the basis of this).

7.9.5.3.

For each of the Priority Impacts identified above the Report should include:

1. Reference to relevant legal and policy requirements highlighting where impacts may approach or exceed regulatory thresholds;
2. Quantitative information on the predicted scale of each impact (allowing for the incorporated mitigations);
3. Consideration of how individual impacts may combine to produce cumulative effects.
4. A description of receptors where there is the potential to be significantly affected by the project (in particular - population, fauna, flora, soil, water, air, climatic factors, material assets (including heritage), and any interaction between them);
5. A description of the forecasting methods used;
6. An indication of any difficulties (technical difficulties or lack of know-how) encountered in compiling the required information;
7. An outline of any missing or incomplete knowledge.

7.9.6.1.

1. Statement of Need
   1. Information about the need for the equipment or service and any alternatives that have been considered (the URD (User Requirement Document) and SRD (System Requirement Document) should form the basis of this).
2. Description of the Equipment or Service and Potential Priority Impacts
   1. The methodology or methodologies that have been used for the assessment including a summary of the scope of the assessment.
   2. A description of the equipment’s or service’s physical characteristics.
   3. A description of the main characteristics and impacts of any proposed testing, trials or demonstration activities.
   4. A description of the main characteristics and impacts of the manufacturing processes, for instance the nature and quantity of the materials used.
   5. An estimate, by type and quantity, of expected releases and emissions (including water, air and soil pollutants, noise, vibration, light, heat and radiation) from the in-service stage for the system. NB the in-service stage includes: Operation, (Normal, Abnormal, Emergency) and Maintenance (Routine, Deep/Repair, Up-grade).
   6. Consideration of issues and impacts associated with the disposal of the system at the end of its life highlighting where impacts may exceed regulatory requirements.
3. For each of the Priority Impacts identified above the Report should include:
   1. Reference to relevant legal and policy requirements highlighting where impacts may approach or exceed regulatory thresholds.
   2. Quantitative information on the predicted scale of each impact (allowing for the incorporated mitigations).
   3. Consideration of how individual impacts may combine to produce cumulative effects.
   4. A description of receptors where there is the potential to be significantly affected by the project (in particular - population, fauna, flora, soil, water, air, climatic factors, material assets (including heritage), and any interaction between them).
   5. A description of the forecasting methods used.
   6. An indication of any difficulties (technical difficulties or lack of know-how) encountered in compiling the required information.
   7. An outline of any missing or incomplete knowledge.
4. Mitigation and monitoring
   1. Details of mitigation measures that can be incorporated into the design of the proposed development.
   2. Details of mitigation measures that can be applied to the system to reduce environmental impacts.
   3. A list of any potential mitigation measures that it has not been possible to include, and the reasons why.
   4. Statement of any residual impacts.
   5. Suggested monitoring regimes.
   6. Suggested plan for undertaking any suggested mitigation measures.
   7. An indication of any difficulties (technical difficulties or lack of know-how) encountered in compiling the required information.
   8. Consideration of any positive environmental impacts the project may have and ways in which these can be optimised.
5. Conclusion
   1. Conclusion that outlines for each known or potential priority impact whether:
   2. Suitable mitigation is identified; or
   3. No suitable mitigation is available: the EIM Report should provide evidence that all reasonable and practicable alternatives were explored in a structured and documented manner; and
   4. The nature and scale of any residual impacts.

7.9.7.1.

EIM Reports can vary widely in layout and content. However, the list below can be used to check that the Report meets existing good practice.

1. Does the report include a systematic approach to the gathering and analysis of information?
2. Is the information presented in a clear, comprehensive and objective manner?
3. Is there a relatively concise main report that draws on the technical studies and summarises them as necessary?
4. Is there sufficient cross referencing for the reader to make the links between the Non-Technical Summary (EIS), the main report, appendices, and any separate studies?
5. Is the attention given to environmental issues proportional to their potential impacts, and are those aspects with insignificant impacts also identified?
6. Are mitigation measures presented as a prioritised list?
7. Are mitigation measures described in appropriate detail and timetabled?
8. Does it state the means by which monitoring will be carried out?
9. Are the methods by which the analysis was carried out and the EIM Report prepared explained?
10. Are the credentials of the authors/contributors involved stated?
11. Are detailed technical studies contained in appendices?
12. Is the 'Non Technical Summary' (EIS) a summary in every-day language?

Note: The above has been developed using existing good practice from a range of Standards Bodies and Government Departments including the MOD.