Turning Commitments into Action
A mitigation measure written in an EIA has little value if it never makes its way to the real world.
A typical EIA will contain a range of mitigation and monitoring measures to be implemented during the construction and operational stages of the project. These measures, along with conditions outlined in the environmental permit, need to be translated into actions during construction, and project operation.
During construction, the environmental consultant’s role extends beyond checking whether the measures identified in the EIA have been implemented. Environmental consultants work with the contractor and wider project team to assess what is happening on the ground and respond to changing conditions. This can include:
- Identify problems before they become environmental incidents
- Introduce additional monitoring measures to suit project needs
- Adapt existing mitigation measures when site conditions change.
For example, if a protected species is unexpectantly encountered during construction, the environmental consultant on site may need to pause the works in the area, introduce a species-specific translocation or protection and management plan. Additionally, the consultant will coordinate with the environmental regulatory authority to ensure the measures are adequate and agree on any additional protection measures before resuming construction works.
Environmental monitoring, site inspections, compliance audits, and corrective actions are examples of tools used to assist the environmental consultant in making assessments and taking decisions. As such, the environmental consultant’s role during construction is dynamic, so they are expected to continuously assess the situation on the ground and determine whether the environmental measures identified at the EIA stage remain appropriate for the current site conditions, or whether additional action is required.
And implementation does not stop when construction is complete.
Environmental management continues throughout the operational life of a project. At this stage, the role of the environmental consultant will mostly be to use inspections, audits, and monitoring results and assess whether the measures put in place are still effective and appropriate for the project, and its operating conditions. This includes checking whether:
- Mitigation measures are still effective
- Permit conditions are being followed
- Monitoring requirements remain appropriate, and are being adhered to
Importantly, the consultant also needs to consider whether the operating environment itself has changed. Any changes in operations, surrounding developments, environmental conditions, or regulatory requirements can alter the risks identified during the original assessment, and will require additional assessments and measures to be undertaken.
For example, if a new residential development is built closer to the project when it is in its operational phase, the noise and air quality impacts – previously assessed and mitigated – might need to be reassessed after the introduction of new sensitive receptors. This could introduce additional mitigation measures which were not applicable at the time of the original EIA assessment.
Another example would be when the regulatory thresholds for emissions are tightened after the project is operational. The environmental consultant will, therefore, need to reassess the existing controls in place, and may need to introduce additional mitigation and monitoring measures.
This demonstrates the dynamic nature of environmental consultancy: It is not about making a decision at one point in the project lifecycle and assuming it will remain valid indefinitely, but rather continuing to monitor, assess, and reevaluate environmental conditions to ensure the decisions taken are still valid and representative.
