Author: Petra Stock
An Environmental Management Plan (EMP) document is often part of the detailed assessment phase – either as a planning permit condition or as a part of the development application.
It brings together all the environmental commitments, management and mitigation measures from the development application into one document. Usually covering wind farm construction and operation phases, an EMP also sets out a structured approach for implementing these measures, checking implementation and documenting the results.
A lay-person can write the EMP, by following the standard AS/NZS ISO 14001 Environmental Management Systems – Specification for guidance and use (Standards Australia / Standards New Zealand 2004). If a member of your community group writes the EMP, it will be significantly cheaper than hiring an expert consultant, but make sure they have the time to commit to the project.
What to include in an Environmental Management Plan
The EMP provides details about how environmental commitments, management and mitigation measures will be implemented during construction and operation.
As an example, if the flora and fauna report recommends no clearance of native vegetation, the EMP would outline the location of native vegetation on site and set out protection procedures, such as marking these areas with high visibility tape.
As a guide, here is what your EMP should contain:
- Environmental policy — a statement of your overall environmental management philosophy.
- Legislation and standards — a summary of the key environmental legislation that applies, and any relevant guidelines and standards.
- Environmental aspects and impacts — this can be a summary of the potential impacts identified in the environmental and technical reports.
- Objectives and targets — setting out key objectives and measurable targets for each environmental issue.
- Consultation and communication — detailing arrangements for communicating key elements of the EMP, and a process for registering and dealing with complaints from the community.
- Monitoring — details of any onsite monitoring, such as water quality monitoring. This may include a weekly or monthly checklist for environmental aspects you can’t monitor scientifically.
- Incidents and non-conformance — explains what will happen if EMP procedures aren't followed.
- Emergency procedures — details steps for dealing with emergencies onsite, such as a chemical spills, including who to contact.
- Documentation and reporting — provides a structured approach to managing documents relating to the EMP, version control, audit reports. This also sets out internal and external reporting arrangements for implementing the EMP.
- Responsibilities — allocates environmental responsibilities to the construction team, subcontractors and management.
- Training — sets out the necessary environmental training for all staff at the wind farm site and in the office.
- Audits — sets out when audits of the EMP will occur and what they should cover. This usually involves regular internal audits during construction (perhaps monthly) and some external audits by consultants (once or twice during the construction phase).
While it's important to address all the requirements set out in AS/NZS ISO 14001 Environmental Management Systems, you do not have to prepare large amounts of documentation. Remember, it's the construction and operation crews who will implement the EMP, so try to write clearly and succinctly for their benefit.
Who to consult
When you prepare your EMP, it's useful to consult the relevant government authorities for each environmental issue. Authorities may include:
- the state environmental protection agency or authority
- state environment, cultural heritage and threatened species departments
- the local government planning and environmental officer
- local water authorities, including water supply and treatment organisations and catchment management authorities
- local emergency services, such as fire, police, fire and ambulance
- local Aboriginal representatives.
You can also offer these organisations the opportunity to comment on your draft EMP.