CIV 4204: ENVIRONMENTAL QUALITY MANAGEMENT

Course outline
o Introduction and definitions
o Environmental policies and guidelines (water and effluent discharge standards)
o ENVIRONMENTAL IMPACT ANALYSIS
o Environmental monitoring of construction works
o Water pollution control
o Waste load allocations
o Air pollution control
o Noise pollution
o Wetlands protection
o Control of land/soil pollution

3: ENVIRONMENTAL IMPACT ANALYSIS

3.1 SOME DEFINITIONS

Human environment can be interpreted to comprehensively include the natural and built up
environment and man’s relationship with that environment.
Impacts (or effects) - these include ecological (natural resources and the components, structure,
and functioning of the ecosystem), aesthetic, historic, economic and health effects. They may be:
• Direct – caused by the action and occur at the same time and place as the project for
example, displacement of persons for dam and reservoir construction.
• Indirect – caused by action but may occur in different place at another time, although
still reasonably foreseeable for example, the sinking of borehole lowers the water table
which may result in die-off of vegetation miles away.
• Cumulative – continued action of the project compounds the present impact or future
impact.
Environmental impact assessment (EIA) is defined as the systematic examination conducted
to determine whether or not a project will have any adverse impact on the environment (National
Environment Statue, 1995). Following an EIA, a concise public document for which the
government is responsible is prepared. The document serves to
i) Briefly provide evidence and analysis for determining if an Environmental Impact
Statement (EIS) is required if the findings are of no significant impact
ii) It aids the agency’s compliance with the government Environment Policy act when no
EIS is necessary
iii) It will facilitate the preparation of the EIS if necessary
The EIA also includes a brief discussion of the need for the project, the alternative options, and
the persons consulted.
Environmental impact statement (EIS) is a detailed written statement, quite similar to the EIA
but greater in depth and detail.

3.2 OBJECTIVES OF AN EIA

i) To identify whether or not (YES or NO) a proposed policy, project or activity is likely to
have significant impacts (both beneficial and adverse)
ii) If YES, to identify the potential significant environmental impacts
iii) Analyse the significance of the adverse environmental impacts
iv) Determine whether the adverse impacts can be mitigated
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 v) Recommend preventive or mitigation measures
vi) Identify and assess any other alternatives of the proposed policy, project or activity and
associated activities.
vii) Recommend whether or not the proposed project should be implemented or modified.

3.3 WHEN DOES ONE NEED AN EIA?

• In the preliminary stages of a project
• To determine possible impacts of the project on the environment
• To establish any possible impact reductions, improvements etc.

The principal components of the environment are highlighted in the Table 1. However, an EIA
can also be prepared using categories of environmental parameters under the following broad
categories: Physical/chemical, ecological, aesthetics and social.

Table 1 Principal components of the environment

Social
Services Safety Sense of community
Education facilities Structures Structural organisation
Employment Materials Homogeneity and diversity
Commercial facilities Site hazards Physical stock and facilities
Healthcare/ Social services Circulation conflicts
Liquid waste disposal Road safety and design Psychological well-being
Solid waste disposal Physical threat
Water supply Physiological well-being Crowding
Storm water drainage Noise Nuisance
Police Vibration
Fire Odour Historic value
Recreation Light Historic structures
Transportation Temperature Historic sites and districts
Cultural facilities Disease
Visual quality
Visual content
Formal coherence
Apparent access
Physical
Geology Special features Biota
Unique features Sanitary landfill Plant and animal special lists
Resource value Wetlands Vegetation community types
Slope stability/rock fall Coastal zones/shorelines Diversity
Foundation stability Mine dumps/spoil areas Productivity
Depth of impermeable layers Nutrient cycling
Subsidence Water
Weathering/chemical release Hydrologic balance Climate and air
Tectonic activity/volcanism Aquifer yield Macroclimate hazards
Groundwater recharge Forest and range fires
Soils Groundwater flow direction Heat balance
Slope stability Depth to water table Wind alteration
Foundation support Drainage/channel form Humidity and precipitation
Shrink swell Sedimentation Generation and dispersion of contaminants
Frost susceptibility Impoundment leakage
Liquefaction and slope failure Shadow effects Energy
Irritability Flooding Energy requirements
Permeability Water quality Conservation measures
Environmental significance

3.4 WHAT SHOULD AN EIA COMPRISE OF?

I A description of proposed action and alternatives. Listed below are some possible activities
and the issues, which the EIA would look at under each:
a) Land use and transformation – wetland reclamation, flooding, destabilisation of
populations
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 b) Resource extraction – mining, deforestation, fishing
c) Resource renewal – afforestation, fish culture
d) Agriculture – pesticides, fertilisers, deforestation
e) Transportation – road construction, railway construction, bridges, airports, ports
f) Water treatment and disposal – receiving waters, lagoons, ponds, seepage
g) Recreation – game Park lodges, tourism, golf course, diseases transmission, culture
change, mass movement of persons.
II An estimate of the nature and magnitude of likely environmental changes including action-
induced effects.
III An identification of human concerns, i.e., who and/or what will be affected and what will be
changed. These include:
a) Economical and occupational status
b) Social pattern and life style
c) Social amenities and relationships – some constructions related to social amenities such
as football pitches, golf clubs, social clubs, etc, may cause behavioural and language
changes (slang development)
d) Psychological features – involvement, stress, expectations, frustrations
e) Physical amenities – may be intellectual, cultural, aesthetic – museums, art galleries,
national parks
f) Health – increase or reduction of disease incidences
g) Personal security – protection from natural disasters, for example, cyclones, floods
h) Religious and traditional beliefs – taboos, morals of the society
i) Technology – can offer security of put persons at risk – occupational hazards, mining,
nuclear hazards
j) Cultural concerns – Leisure, fashion, clothing, heritage, traditional rights
k) Political – decision making, setting of policy, resource allocation, overall authority
l) Legal implications – restructuring of public concerns, changes in taxation, policy
m) Statutory Laws and Acts – air and water quality standards, noise abatement Acts,
building regulations, definition of legal terminology etc.
n) Aesthetics – visual physical changes, noise, smells.
IV Definition of criteria for measuring and grading significant changes and relative weighting
for comparison of different changes. These may be:
− Subjective, e.g., very bad – bad – fair – good – very good
− logically weighted for, e.g., 0(very bad) – 1 – 2 – 3 – 4 – 5 – 6 (very good)
− comparison with standards, e.g., results of lab analysis of samples, visual inspections
V Estimation of the significance of the predicted changes by summing up all the impacts and
weighing the project proposal according to the set limits or goals.
VI Preparation of proposals for:
− acceptance for the project by the community
− remedial action to avert/alleviate negative impacts
− one or more viable alternative methodologies
− rejection of the project.
VII Preparation of recommendations for inspection/monitoring procedures after action has been
taken to check whether the project impact will be as anticipated.

3.5 THE EIA PROCESS

The EIA process has three phases (Figure 1). These are detailed below.
1 Screening phase
This determines the level of EIA that is required. It helps in deciding whether a proposed project:
a) will certainly not have significant impacts on the environment and should therefore be
exempted from EIA processing.

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b) may have impacts on the environment but these impacts are easily identifiable and can be
mitigated.
c) will certainly have significant impacts on the environment and therefore a full environmental
impact study is required.

2 Environmental Impact Study

This includes:
a) Scoping: This refers to the early open identification of potentially significant environmental
impacts and de-emphasis or elimination of insignificant impacts or impacts which have
already been covered by other EIAs. This is done in consultation with the Authority, Lead
agency and all other stakeholders.
b) Conducting the EIStudy and preparation of EIS.

3 Decision Making
This is by the Authority in consultation with the Lead Agency. Its three components are:
a) Review of Environmental study findings basing on the EIS, its level of address of the TOR
and Stakeholders/Public comments.
b) Approval (or disapproval) of the EIS by the Authority: This will be based on the review in
(a) above following, which a certificate of approval (with or without attached conditions) of
the EIA will be issued.
c) Record of Decision: It is a document prepared for the developer indicating approval or
disapproval of the environmental aspects of the EIS.

Thereafter the developer will be licensed if the proposed action is approved.

3.6 LEVEL OF DETAIL REQUIRED OF AN EIA

The required level of detail of an EIA depends on:
1) Sensitivity of the local environment, e.g., discharge of toxic wastes in an inhabited area, as a
last resort, will require a more detailed EIA than, say, disposal in the middle of the Sahara
desert.
2) Scale and potential effects of the proposed developments, e.g., in rural or urban area impacts
may differ.
3) Social value attached to conserving environmental quality locally, nationally and
internationally. Some nations for example may afford to spend millions of dollars to protect
their environment. Also architectural relics, historical sites, traditional burial grounds, etc.,
may overrule urbanisation.
4) Resources and scientific expertise locally available.
5) Available time in which to produce the document (set time limits, deadlines).

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 DEVELOPER Inputs/Outputs

Submission of project Project Brief forwarded

brief to the Authority to Lead Agency

Authority and Lead

Agency consultation on
SCREENING

Screen1 Screen2 Screen3 Project Brief

(Annex 2) (Annex 3) Whether adequate
Whether project is Whether project mitigation measures Certificate of Approval
exempt from EIA requires mandatory have been of EIA
EIA incorporated

Stakeholder
Scoping
consultations on scope

TORs Authority, Lead Agency

EISTUDY

and Stakeholder
Review of TORs consultations on TORs
Public and stakeholder
EIStudy and collection of information consultations

Prepare EIS EIS

Lead Agency and

Public comments
DECISIONS

Review and comment on EIS

and review
Approval of EIS Any further stakeholder
and Lead Agency
Decision on Project comments

Record of Decision
Action by DEVELOPER

Figure 1 Schematic representation of the EIA process

3.7 TOOLS USED IN PREPARING AN EIA

Some of the tools used by assessors preparing EIA include
• Field surveys
• Questionnaires, public opinion polls
• Modelling (computer aided simulation)
• Agency guidelines (may vary from agency to agency, NEMA in the case of Uganda)
• Literature searches
• Workshops
• Interviews with specialists (brainstorming)
• Monitoring before and after project establishment, continuous assessment, use of a pilot
project or model.

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3.8 EXPERTISE REQUIRED FOR ENVIRONMENTAL IMPACT ASSESSMENT
It is obvious that knowledge of environmental components and impacts of various activities on
these components is not the monopoly of any one discipline. For this reason, the EIA on any
project is usually carried out and a report compiled by a multidisciplinary team of specialists in
the various fields. The team may include the following expert personnel: environmental
engineer, socio-economist, environmental scientist, health worker, anthropologist,
hydrogeologist, land resource economist, etc.

3.9 RECOMMENDED FORMAT FOR EIA/EIS

1. Project description
a) Purpose of action
b) Description of action
1) Name
2) Summary of activities
c) Environmental setting
1) Environment prior to proposed action
2) Other related state activities
2. Land-use relationships
a) Conformity or conflict with other land-use plans, policies and controls
1) National, regional and local
2) Existing environmental pollution control legislation
b) Conflicts and/or inconsistent land-use plans
1) Extent of reconciliation
2) Reasons for proceeding with action in spite of conflict

3. Probable impact of the proposed action on the environment

a) Positive and negative effects
1) National and international environment
2) Environmental factors
3) Impact of proposed action
b) Direct and indirect consequences
1) Primary effects
2) Secondary effect

4. Alternatives to proposed action

a) Reasonable alternative actions
1) Those that might enhance environmental quality
2) Those that might avoid some or all adverse effects
b) Analysis of alternatives
1) Benefits
2) Costs
3) Risks

5. Probable adverse environmental effects, which cannot be avoided

1) Adverse and unavoidable impacts
2) How adverse impacts will be mitigated

6. Relationship between local short-term uses of man’s environment and the maintenance and
enhancement of long-term productivity
a) Trade-off between short-term environmental gains at expense of long-term losses.
b) Trade-off between long-term environmental gains at expense of short-term losses.
c) Extent to which proposed action forecloses future options.
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7. Irreversible and irretrievable commitments of resources
Unavoidable impacts irreversibly curtailing the range of potential uses of the environment.
1) Labour
2) Materials
3) Natural
4) Cultural

8. Other interests and considerations of national policy that offset the adverse environmental
effects of the proposed plan
a) Counter weighing benefits of the proposed action.
b) Counter weighing benefits of alternatives.

Every EIA should have an executive summary. Chapters included are:

1. Introduction-Give the background, justification, objective and describe the intended
project
2. Methodology
3. Description of existing environment
4. Legal and regulatory framework
5. Mitigation measures
6. Environmental monitoring plan.

PUBLIC PARTICIPATION IN EIAs

It is widely accepted that public participation can make a key contribution to the sound design,
effective implementation and efficient operation and management of development projects. All
stakeholders should be involved to the fullest possible extent in the development process, from
the inception, design and development of a project through its implementation, monitoring and
evaluation.

Environmental impact assessment provides an important opportunity to facilitate public

participation, which can also help to improve the quality and effectiveness of the environmental
assessment process itself. Whilst the integration of participatory approaches into environmental
assessment will not in itself guarantee effective EIA, public participation offers a wide range of
potential benefits. Experience shows it can:
• help the EIA address relevant issues, including those perceived as being important by
local communities, affected groups and other stakeholders;
• help to harness traditional knowledge which conventional approaches often overlook;
• help improve information flows between proponents and stakeholder groups, improving
the understanding and “ownership” of a project.
• enable local communities to influence project design, so that the project responds to their
needs;
• help identify important environmental characteristics or mitigation opportunities that
might be overlooked;
• help ensure that the magnitude and significance of impacts has been properly addressed;
• improve the acceptability and quality of mitigation and monitoring process.

Terms such as consultation and participation are often used interchangeably or perceived and
applied in ways that vary between different agencies. The distinction between the two lies in the
degree to which the public and other stakeholder groups are allowed to influence, share or
control the decision-making process. To date, approaches to involving the public in the cast
majority of project level EIAs have been characterised by passive or extractive interactions

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between the public and EIA practitioners, in which the public have little opportunity to take part
in, or influence project design or decision-making. Such approaches can at best be described as
consultation. There are few examples of participatory EIA, despite the abundance of rhetoric
included in development agency guidelines.

Determining who participates requires careful thought because potential stakeholders will often
represent different social groupings, religious affiliations, genders and constituencies. Each can
contribute in different ways, and may advocate different priorities based on individual needs,
motivations and interests. Stakeholder analysis techniques can be used to develop an
understanding of who the key stakeholders and actors and what their respective interests are.

Powerful, influential and wealthy groups tend to have better access to decision-making
processes, and care is required to ensure that their views do not dominate over those of poor,
affected or marginalised groups. Balancing the needs of heterogeneous groups will first required
a careful analysis of appropriate stakeholders as a basis for determining approaches that are
tailored to local conditions and needs.

Public participation is frequently introduced into the EIA process at a late stage, but the rationale
for this is often reactive rather than proactive-aiming to convince stakeholder groups of the
merits of a particular initiative for public relations reasons, rather than trying to establish
constructive engagement with different stakeholder groups. Experience shows that early
integration of participatory approaches results in a more effective EIA process, especially when
participation is introduced whilst the project design characteristics are still open to modification,
and whilst alternatives are still under consideration.

A number of techniques can be applied to promote and establish dialogue with stakeholder
groups. These include:
• institutional committees and working groups;
• workshops, conferences and round tables;
• advisory groups;
• networking;
• media announcements; local radio phone-ins; newsletters and brochures; public notices,
displays, meetings, telephone service lines;
• collaboration with community NGOs and community leaders; participatory learning and
action techniques;
• surveys, interviews and questionnaires.

Ideally, participation should start at the screening stage-by making outline details of
development plans available to local communities and/or NGOs, in an accessible form, for
example. Scoping provides the opportunity for participants to ensure that the terms of reference
for the EIA process address all issues perceived to be of importance and to optimise and provide
for the involvement of different stakeholders groups. Once such terms of reference have been
defined, the opportunities for the public to influence the process diminish markedly.
Opportunities for integrating participation approaches throughout the EIA process also exist, for
example through joint assessment, whereby different stakeholders work with EIA practitioners to
negotiate and agree on issues relevant to decision-making. Dissemination and public review of
the draft EIA documents can help identify issues that have been `missed´ or addressed
inadequately.

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 ANNEX 2
LIST A: PROJECTS, WHICH ARE LIKELY TO BE EXEMPTED FROM THE EIA PROCESS

The following list identifies those projects, which are normally exempt from the EIA process. The characteristics
and anticipated physical effects of each project should be carefully considered when or if they are exempted from
further steps of the EIA process.
• Clearing and farm construction for individual subsistence small farms.
• Construction or repair of individual houses.
• Minor land use changes in areas with slopes less than 20% including housing construction.
• Information collection (Scientific or educational) except if it involves use of chemicals or endangered
species or alien materials.
• Transfer of ownership of land or related facilities so long as the general character of the area is not
changed.
• Environmental enforcement actions.
• Emergency repairs to facilities within the character of its surroundings.

ANNEX 3
LIST B: PROJECTS TO BE CONSIDERED FOR ENVIRONMENTAL IMPACT ASSESSMENT

The following projects are listed in The National Environment Statue, 1995, Schedule 3, as those for which an EIA
shall be conducted.

1. General-
a) an activity out of character with its surroundings;
b) any structure of a scale not in keeping with its surroundings;
c) major changes in land use.

2. Urban development including-

a) designation of new townships;
b) establishment of industrial estates;
c) establishment or expansion of recreational townships in mountain areas, national parks and game reserves;
d) shopping centres and complexes.

3. Transportation including-
a) all major roads;
b) all roads in scenic, wooded or mountainous areas;
c) railway lines;
d) airports and airfields;
e) pipelines;
f) water transport.

4. Dams, rivers, and water resources including-

a) storage dams, barrages and weirs;
b) river diversions and water transfer between catchments;
c) flood-control schemes;
d) drilling for the purpose of utilising groundwater resources including geothermal

5. Aerial spraying
6. Mining, including quarrying and open-cast extraction of-
a) precious metals;
b) diamond;
c) metalliferous ores;
d) coal;
e) phosphates;
f) limestone and dolomite;
g) stone and slate;
h) aggregates, sand and gravel;
i) clay;
j) exploration for the production of petroleum in any form

7. Forestry related activities including-

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 a) timber harvesting;
b) clearance of forest areas;
c) reforestation and afforestation.

8. Agriculture including-
a) large scale agriculture;
b) use of new pesticides;
c) introduction of new crops and animals;
d) use of fertilisers.

9. Processing and manufacturing industries including-

a) mineral processing, reduction of ores and minerals;
b) smelting and refining of ores and minerals;
c) foundries;
d) brick and earthenware manufacture;
e) cement works and lime processing;
f) glass works;
g) fertiliser manufactures and processing;
h) explosives plants;
i) oil refineries and petro-chemical works;
j) tanning and dressing of hides and skins;
k) abattoirs and meat-processing plants;
l) chemical works and process plants;
m) brewing and malting;
n) bulk grain processing plants;
o) fish processing plants;
p) pulp and paper mills;
q) food processing plants;
r) plants for the manufacture or assembly of motor vehicles;
s) plants for the construction or repair of aircraft or railway equipment;
t) plants for the manufacture or processing of rubber;
u) plants for the manufacture of tanks, reservoirs and sheet-metal containers;
v) plants for the manufacture of coal briquettes.

10. Electrical infrastructure including

a) electricity generation stations;
b) electrical transmission lines;
c) electrical sub-stations;
d) pumped storage schemes.

11. Management of hydrocarbons including-

the storage of natural gas and combustible or explosive fuels.

12. Waste disposal including-

a) sites for solid waste disposal;
b) sites for hazardous waste disposal;
c) sewage disposal works;
d) major atmospheric emissions;
e) offensive odours.

13. Natural conservation areas including-

a) creation of national parks, game reserves, and buffer zones;
b) establishment of wilderness areas;
c) formulation or modification of forest management policies;
d) formulation or modification of water catchment management policies;
e) policies for management of ecosystems, especially by use of fire;
f) commercial exploitation of natural fauna and flora;
g) introduction of alien species of fauna and flora into ecosystems.

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 AN INTRODUCTION TO ENVIRONMENTAL AUDITING
(Julian Holbrook, 1996; http://www.snh.org.uk/)

1. Introduction
1.1 There is now a range of practices which come under the label of environmental auditing. This
introduction is therefore made of an activity, which is of increasing interest in the public and
private sector.

2. Background
2.1 Environmental auditing originated in the United States in the 1970s. At first reactive in
focus, environmental considerations were dealt with by 'end of pipe' solutions. Control measures
were heavily influenced by the need to reduce remediation costs and fines which might stem
from industrial accidents, and from the need to manage environmental liabilities.

2.2 Environmental auditing was introduced to the UK and elsewhere mainly by multi-national
companies who began to apply the audit procedures corporately and via subsidiaries
(horizontally). It is now being encouraged down the supply chain when large companies demand
that their suppliers have green credentials (vertically). Environmental auditing has also become
more proactive as organisations have recognised potential market and stakeholder benefits,
efficiency gains, financial savings, and the importance of improved public relations.

2.3 Historically, environmental auditing has been developed for industrial (chemical and
manufacturing) applications. Interest has also occurred in the public sector, resulting from the
various Charter initiatives to open up activities to greater public scrutiny. Local authorities now
apply auditing in their work. This can be expected to grow more rapidly as a result of new
commitments towards sustainable development and the implementation of Local Agenda 21.

3. Definitions
3.1 The term 'environmental auditing' is broad. Many definitions cover auditing in the private
and public sector.

3.2 Private sector environmental auditing has been variously defined as:
'a management tool comprising a systematic, documented, periodic and objective evaluation of
the performance of the organisation, management system and processes designed to protect the
environment with the aim of:
(1) facilitating management control of practices which may have impact on the environment, and
(2) assessing compliance with company policies' (CEC, 1993); and
(3) the systematic examination of the interaction between any business operation and its
surrounding.
This includes all emissions to air, land and water legal constraints; the effects on the
neighbouring community, landscape and ecology; and the public's perception of the operating
company in the local area' (CBI, 1990).

3.3 Many types of audit have been carried out by companies (ERM, 1996, Thompson and
Therivel, 1991):
• compliance audit - the most common type of audit consisting of checks against
environmental legislation and company policy;
• issues audit - an evaluation of how a company's activities relate to an environmental issue or
(e.g. global pollution, energy use) or an evaluation of a specific issue (e.g. buildings,
supplies);

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• health and safety audit - an assessment of risks and contingency planning (sometimes
merged with environmental auditing because of the interconnected impacts of industrial
processes and hazards);
• site audit - an audit of a particular site to examine actual or potential environmental
problems;
• corporate audit - an audit of the whole company and its policies, structures, procedures and
practices;
• due diligence audit - an assessment of potential environmental and financial risks and
liabilities carried out before a company merger or site acquisition or divestiture (e.g.
contaminated land remediation costs);
• activity or operational audit - an assessment of activities that may cross company
departments or units (e.g. energy or waste management) and
• product or life cycle audit - an analysis of environmental impacts of a product throughout
all stages of its design, production, use and disposal, including its reuse and recycling (cradle
to grave).

3.4 The above have been described as partial environmental audits (Welford and Gouldson,
1993) to distinguish them from the more specific environmental audit and, in particular, the
periodic audit that forms a crucial step in environmental management systems (EMS). Each is
discussed below in sections 4 and 5 respectively.

3.5 In the public sector, local authorities have led the way in environmental auditing. Two forms
have been defined (LGMB, 1991):
External audit - 'An assessment of the condition of the local environment, usually resulting in a
State of the Environment Report (SoE or SOER)' and
Internal audit - consisting of two areas:
• 'Policy Impact Assessment - a review of the activities (objectives, services, practices and
policies) of the authority' and
• 'Management Audit - a review of the procedures and structures by which environmental
policies are managed by the authority'.

3.6 'Strategic Environmental Assessment' (SEA) has emerged in recent years as a way of
appraising the environmental impacts of policies, programmes and plans (Bedfordshire County
Council/RSPB, 1996). As such it is a method for Policy Impact Assessment. Many local
authorities in England and Wales have undertaken or are currently preparing one (Therivel,
1994,). In Scotland SEA was piloted in Gordon District in 1994, followed by Clackmannan
District Council in 1995. SEA is also being explored as a way of identifying the potential
environmental impacts of some of the Structural Fund Programmes (Objective 1, 2 and 5B).

4. Environmental auditing practice and procedures

4.1 The more specific type of environmental audit involves the collection, collation, analysis,
interpretation, and presentation of information which is used to:
• assess performance against a set of requirements or targets, related to specific issues;
• evaluate compliance with environmental legislation and corporate policies; and
• measure performance against the requirements of an environmental management system
standard.

4.2 The systematic, periodic, documented and objective aspects of environmental auditing are
fundamental to effectiveness. It is fast developing as an important and powerful tool in the
corporate environmental assessment and management toolkit. The requirement periodically to
repeat audits ensures that there is an ongoing commitment and a systematic process to improve
environmental performance (Grayson, 1992). The scope of repeat audits can also broaden to
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become more comprehensive as experience and expertise are accrued or as new issues or
legislation emerge.

4.3 Sometimes the terms assessment, appraisal, monitoring or review have been used
interchangeably with audit. Audit implies detailed statistical verification with a periodic cycle
between audits. An assessment or review is usually a one-off event which is carried out in less
detail and with less direct checking of data.

4.4 Environmental Reviews provide a baseline overview of current environmental effects or

impacts, relevant environmental legislation and a statement of existing environmental
performance. The Reviews provide a basis for establishing a management action plan. They can
become part of an environmental management system to help implement the plan. When they are
undertaken as the first of a series of periodic environmental audits they have been referred to as a
'Baseline Environmental Audit'.

4.5 Environmental audits should be appropriate to the particular circumstances. As

environmental auditing draws upon various methodologies, each organisation will define its own
system depending upon its size, its activities and its corporate culture. The scope and style of
audits vary, but common stages and activities include:

Pre-audit stage
• full management commitment;
• setting overall goals, objectives, scope and priorities;
• selecting a team to ensure objectivity and professional competence;
Audit stage
• on-site audit, well defined and systematic using protocols or checklists;
• review of documents and records;
• review of policies;
• interviews;
• site inspection;
Post- audit stage
• evaluation of findings;
• reporting with recommendations;
• preparation of an action plan; and
• follow-up.

4.6 There is an increasing demand for the results of auditing to be disclosed. Recent European
initiatives on access to environmental information (CEC, 1990) and the requirement of the Eco-
Management and Audit Scheme (CEC, 1993) for participants to publish environmental
statements confirm the importance of this.

5. Environmental Auditing and Environmental Management Systems (EMS)

5.1 An EMS is a tool designed to enable organisations to target, achieve and demonstrate
continuous improvement in environmental performance. It is one integrated management process
with a number of stages, which includes an environmental audit. There are a number of standards
(e.g. the British Standard BS7750 (BS11992), the European Eco-Management and Audit Scheme
for Industry (CEC, 1993) and the DoE Eco-Management and Audit Scheme for UK Local
Authorities (DoE, 1995)). These consist of most or all of the following elements depending on
the standard, to:

1. adopt an environmental policy to confirm and promote commitment to continual

improvement in environmental performance;
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2. undertake an environmental review to identify significant environmental issues and effects;
3. set up environmental programmes of objectives, targets and actions;
4. establish an environmental management system to ensure the implementation of the
necessary actions to achieve these objectives;
5. undertake periodic environmental audits to assess the performance of such components;
6. prepare an environmental statement on environmental performance; and
7. obtain independent verification of the environmental statement.

5.2 Many companies have set up internal environmental standards which are applied world-wide.
These may be more stringent than local legislation.

6. Public sector environmental auditing (example of Scotland)

6.1 Increasingly, public sector bodies and local authorities are adapting auditing methods to
establish baselines of environmental performance. These then inform management action.

6.2 Interest and action was stimulated in the late 1980s by the Friends of the Earth (1989). A
number of authorities prepared environmental charters, follow-up environmental strategies and
action plans, which are generally referred to as Green Plans (Raemaekers et al., 1991 and
Raemaekers, 1993). It was not long before leading authorities also realised the greater corporate
performance and environmental benefits of the broader and deeper approaches of the internal and
external auditing (COSLA, 1992).

6.3 In 1989, the first local authority environmental audit was undertaken by Kirklees District
Council with the assistance of Friends of the Earth. Since then a number of Scottish local
authorities have produced environmental audits, notably Fife and Grampian Regional Councils,
Ross and Cromarty, Gordon, Falkirk, Clackmannan and Dundee District Councils. The scope of
public sector audits is different from that of the industrial sector in that the effects of service
provision are considered as well as the direct effects of the activities of the local authority:
• Direct effects - environmental impacts that result from the way in which day to day activities
are undertaken. Direct effects are covered by internal management audit.
• Service effects - environmental impacts that result from the organisations efforts in
implementing environmental policies and objectives. They would be covered by the Policy
Impact Assessment type of audit.

6.4 Additionally, audit techniques have been adapted to prepare State of the Environment
Reports. After several authorities, including Fife Regional Council and Ross and Cromarty
District Council, piloted the approach, the DoE published a guide to implementing
environmental management systems within local authorities. It is referred to as UK-EMAS, as it
was derived from the European Eco-Management and Audit Scheme (DoE, 1993).

6.5 Typically public sector audits cover a number of target areas such as:
• energy use;
• recycling;
• hardwoods from sustainable sources;
• environmental education;
• habitat conservation and creation;
• green purchasing; and
• traffic calming.

6.6 Inevitably there are issues which may have been overlooked or might be misinterpreted, and
further and clearer guidance will be necessary. SNH along with the Countryside Commission

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and the Countryside Council for Wales have commissioned guidance on the treatment of
countryside and conservation issues within State of the Environment Reports (SNH, in prep).

7. The benefits of auditing

7.1 While environmental audits are designed to identify environmental problems, there may be
widely differing reasons for undertaking them: compliance with legislation, pressure from
suppliers and customers, requirements from insurers or for capital projects, or to demonstrate
environmental activities to the public. The benefits of environmental auditing include:
• ensuring compliance, not only with laws, regulations and standards, but also with company
policies and the requirements of an Environmental Management System (EMS) standard;
• enabling environmental problems and risks to be anticipated and responses planned;
• to demonstrate that an organisation is aware of its impact upon the environment through
providing feedback;
• increased awareness amongst stakeholders; and
• more efficient resource use and financial savings.

8. Trends/future developments
8.1 Audit programmes are becoming a standard environmental management tool and pressures
for the disclosure of audit results are increasing. Public statements of environmental information
with external validation are required by those participating in the European or local authority
Eco-Management and Audit Scheme.

8.2 The utility of environmental audits vary from organisation to organisation. It is likely that
audits will be used increasingly to:
• provide baseline information to enable organisations to evaluate and manage environmental
change, threat and risk;
• form the basis for initiating and monitoring the performance of Environmental Management
Systems;
• contribute to environmental management approaches which become integrated with
environmental impact assessment and the management of predicted impacts, mitigation and
monitoring measures;
• support the implementation and management of integrated pollution control procedures and
assist in the definition of 'best practicable environmental options' (BPEO);
• tackle external off-site impacts which consider the broader environmental footprint of an
organisation's activities; and
• pass environmentally responsible approaches down the supply chain.

8.3 Environmental audits have traditionally dealt with the environmental effects of industrial
processes and, to a lesser extent, with resource consumption. Guided by the legislation and
compliance procedures, the environment has usually been considered in terms of air land and
water. Considerable conservation benefits could be achieved by broadening the focus of auditing
to include natural heritage features and objectives. This would include natural heritage
legislation and by the application of audit techniques to habitats and land use, such as farm units
(Edwards et al.. 1992, LEAF, 1994), forest management units, or sporting estates. Generic
approaches could contribute to the development of conservation management plans.

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 Economic Instruments for Environmental Management in Uganda
(NEMA NEWS, 2004)

Environmental management in Uganda has largely relied on the use of command and control
policies such as; regulations, laws, Environmental Impact Assessments (EIAs) and
Environmental Audits (EAs). Though this approach has been fairly successful, there is evidence
indicating that the costs of additional improvements through this approach are high. For instance
i. the law courts work slowly,
ii. fines are too low to deter violators and
iii. do not induce voluntary compliance.

Therefore increasingly there is a policy shift towards the use of Economic Instruments which can
achieve the same objectives at substantially lower costs.

What are Economic Instruments?

Economic Instruments are market-based instruments that can either be incentives or
disincentives.
Incentives are offered to encourage, motivate or reward good environmental practices.
Disincentives discourage or penalize practices that degrade the environment. Both are aimed at
creating a behavioural change that is favourable to the environment and are not substitutes but
are complements to other environment management tools.

Types of Economic Instruments

1. Property rights
These are entitlements defining owner’s rights and duties in the use of a particular service. These
rights and duties are exercised and enforced and an incentive to invest in natural resource
management or maintaining environmental quality for example land titles and certificates, water
rights, fishing licenses, pollution permit and patent intellectual property rights.

2. Fiscal instruments
These instruments impose taxes (disincentive) or reduce them (incentive). Fiscal instruments are
used to effect full cost-pricing (to bridge the gap between private and social costs and benefits)
for example;
i. environmental taxes
ii. emission and effluent taxes
iii. taxes on inputs and final products
iv. differential tax structure
v. investment tax incentives
vi. subsidies
vii. compensation,
viii. royalties
ix. land-use taxes
x. pollution taxes, etc.

3. Financial instruments
These are extra-budgetary tools financed from aid, external borrowing, debt for nature swaps and
include grants, low interest loans, revolving funds, green or eco-funds.

4. Market creation
This tool attempts to create markets for environmental goods and services. It should be noted
that environment is treated as a free good by many people and therefore not traded and where it

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is traded it is undervalued; leading to its continued degradation. Examples of market creation
include;
i. Tradable certificate of ownership (land)
ii. Tradable water shares
iii. Tradable emission permits (industry)
iv. And tradable offsets/ credits.
This instrument is being used in Uganda in form of carbon credits.

5. Charge systems
Charges are payments for use of resources, infrastructure and services e.g. emission charges,
effluent charges, social waste charges, noise pollution charges, products charges and utility
charges.

6. Performance bonds and deposit refund system

Under this instrument producers and consumers are charged in advance for potential damage to
the environment. Consumers pay a surcharge when purchasing potentially polluting products
which is refunded to them when they return the products or its container to an approved centre
for recycling or proper disposal.

Legal and policy Background for the use of Economic Instruments

The National Environmental Management Policy (1994) and the National Environment Act Cap
153, (NEA) provide for the Polluter Pays Principle (PPP). This provision allows NEMA and the
Ministry of Finance, Planning and Economic Development (MFPED) to recommend the
following; tax incentives to encourage good environmental behaviour including the conservation
of natural resources and abatement of pollution; user fees to ensure that those who use
environmental resources pay the proper value for the utilization of the resource, and tax
disincentive to deter bad environmental behaviour that leads to the depletion of environmental
resources or that cause pollution. In spite of this clear provision, the operationalisation of
economic instruments for environmental management in Uganda is yet to take roots.

Rationale for using Economic Instruments by the industrial sector

i. To compel industries to comply with pollution emission standards;
ii. To influence industries to adopt work methods and technologies that ensure the safety of
their employees and the surrounding environment.
iii. To influence consumers to buy environmentally friendly products.
iv. To encourage innovations into environmentally friendly technologies.

Key principles guiding policy development and implementation strategies for Economic
Instruments
Regulatory measures should be complemented by social and economic incentives and /or
disincentives including pricing to influence behaviour for individual organisations to invest in
sustainable environment management. The enforcement responsibilities of many government
agencies should be reduced to a critical set of regulations which can be effectively enforced. The
tax structure should provide incentives for socially desirable activities and disincentives for
actions which compromise social welfare. Socially Responsible Investment (SRI), based on the
principles of sustainability, should be promoted.

Conditions for operationalisation of Economic Instruments and their applicability to the

Ugandan situation
i. The existence of a legal and /or policy framework that articulates the principles for using
incentives and disincentives and also establishes their levels. This is already available.

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 ii. Mechanisms for penalizing defaulters. These have been established under the NEA
(1995) the various regulations and sectoral laws and regulations.
iii. An institutional framework for resolving conflicts between the polluting and the polluted
parties.
iv. Conflict resolution mechanisms exist under the established courts of law, NEMA and the
collaborative lead agencies.
v. A clear and publicly available statement of the standards set which provide a benchmark
against which any charge above them is justified. Standards have already been set in
different aspects of the environment.
vi. A private sector driven market oriented economy. Uganda has declared its policy towards
a private sector led, market driven and export oriented economy.

Role of the Ministry of Finance and Economic Development (MFPED) in implementing

Economic Instruments for Environmental Management
MFPED together with NEMA with NEMA are expected to spearhead the implementation of
Economic Instruments across all lead agencies and local governments. The Budget framework is
an instrument of the country’s social and economic instruments. Specifically the MFPED is
expected to:
i. Keep the market mechanism under which economic instruments are operationalised and
working. policies which distort the working of the market should be avoided; a stable
macro-economic policy framework in the country is a pre-requisite;
ii. Ensure increased role and participation of the private sector;
iii. Enhance awareness raising on their potential for environmental management and revenue
generation;
iv. Provide technical guidance on how economic instruments can be integrated in the budget
framework;
v. The MFPED, local governments together with NEMA need to raise awareness and
spearhead their implementation; and
vi. Their effects on competitiveness should be taken into account.

Economic instruments have a big potential to reverse environmental degradation facing the
country, raise public revenue and can help to achieve many macroeconomic objectives and
sustainable development objectives. To realise this potential, NEMA, MFPED and other line
ministries, local governments, the private sector, UMA, and the civil society need to work as a
team.

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