How big are your environmental risks?
By Andrew Balch
Every business has the best intentions to be good corporate, social and environmental community members. But in reality, timeframes, budgets and a risk-taking attitude to regulatory compliance mean that many do not live up to that promise. This article is part of an expert series by Andrew Balch on avoiding the pitfalls that commonly befall businesses that fail to effectively manage their environmental responsibilities.
What is the environmental approvals process?
A typical business development process for environmental approvals goes like this…
At the start of the approvals process, good quality management is a top priority, and regulatory processes are usually carefully followed. An environmental impact assessment (EIA) is prepared for the project’s application for an environmental authority (EA) or environmental protection license (EPL).
EIA terms of reference generally call for environmental background monitoring to be conducted as part of the EIA process, to assess the state of the existing environment and to provide a baseline to assess the activity’s future impact against.
This is often where the wheels start to fall off.
Twelve months!? How much will that cost?
For air quality impacts, at least 12 months of meteorological and air quality monitoring is best practice. This data is used in both the EIA approvals process and for future reference once the project is operating.
Very often, the timeframe and budget have not included background monitoring requirements. However, getting a baseline understanding of the environment you are operating in, and are likely to effect in the future, is hugely useful information for your future compliance and for figuring out if all your expensive mitigation equipment is working. It’s also kind of the point of the environmental impact assessment!
On many occasions I have heard proponents demand that their EIA and approvals be achieved in less than a year. Yet, from mines to gas fields, power stations to major industrial plants, I have never seen it happen. Some of these projects with a one-year or shorter timeframe have taken three years, five years, or even longer to emerge from the design, approvals and licensing processes. In fact, there has always been plenty of time to collect a significant environmental background data set.
But my EIA will get through, right?
Once the background data is understood, or sometimes even when it is not, an environmental impact statement is prepared. The air quality impact assessment, though possibly an excellent piece of work, is often based on assumption after assumption, estimate after estimate. Most times at this stage there is little, if any, actual project design information or real data available based on an existing operation.
If framed well, these assumptions will be conservative, and the worst-case impacts will be addressed for future planning, making environmental risk low.
Done badly, and you have just paid thousands of dollars for useless information.
What’s worse is that the regulator reviewing your EIA will spot this failure instantly. Maybe they will let it pass. But you have just flagged that, at least in this area, corners have been cut – and this will colour their perception of the rest of your EIA.
If the regulator feels that background monitoring is critical, and I’ve seen this happen, then they will demand that background monitoring is done. At this stage of the process, the establishment of an air monitoring program can easily add a year to the approvals process.
At this stage I expect you’ll be left wishing it had been done properly in the first place.