Rubin, Kenneth

Schramm, Jack J

OpenSIUC

33THE APPLICATION OF ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) PRINCIPLES TO WATERSHEDSJack J. SchrammKenneth RubinHagler Bailly Services, Inc.BACKGROUND: EVOLUTION OFENVIRONM ENTAL M ANAGEM ENT SYSTEMThere is a worldwide movement today to systematizeenvironmental management.  It has roots in the attempts bythe industrialized world  to come to grips in a managementsense with the vexing environmental crises confronted bysociety over the last thirty years.In the 90's, voluntary systems for environmentalmanagement virtually exploded into view.  The globaleconomy had witnessed increasing reliance on globalstandards in a variety of key industries, includingtelecommunications, electronics, computers, informationmanagement, banking, shipp ing, airline operations, andmaritime operations.  The trend was reflected in theGeneva -based Interna t iona l  Org aniza t ion fo rS t a n d ar d i za t io n  ( I S O) ,  where  env i ro nme nta lrepresentatives from 100 countries agreed on the elementsof an Environmental Management System (EMS) andpromulgated the ISO 14001 EM S Standard (as part of theISO 14000 Series) in September 1996.While the terms of the standard  are directed  to the generic“organization,” it actually grew out of the creation in 1990of the Business Charter for Sustainable Development, anorganization of 50 business leaders.  The standard wasintended to create tools and systems to improve corporateenvironmental performance and safeguard companiesagainst negative impacts on trade and commerce.  Thestandard does not prescribe substantive environmentalperformance requirements from an organization, but,rather, a set of sound environmental managementprocedures.The standard had immediate implications for the globalsupply chain.  Not a regulatory requirement, ISO 14001instead is becoming an advanced form of economicincentive.  Many companies see it in their economic self-interest to adopt a conforming EMS as a passport to theinternational marketplace.The standard reflects a compilation of sound managementprocesses that, together, may be constituted into amanagement framework or become an organizing principlefor a variety of organizations, including those in the publicsector.  The premise of ISO 14001 is that, if an EMS isproperly established and main tained, “continualimprovement” in environmental performance willinevitably result and  the system’s objectives and targetswill be met.This paper argues that the application of EMS principlesto the development and/or the protection of a watershedcan similarly help both the public and private sectors toachieve their goals.  More particularly, they include theefficient integration of water quantity and water quality,environmental as well as human health protection,industrial growth, and the systematic management of waterand related land resources.SUGGESTED COMPOSITION OF ANINTEGRATED M ULTI-MEDIA WATER SHEDEM SThe following management principles are common to allEM Ss:• A policy that articulates a commitment to a specificlevel of environmental performance;• Specific measurable quantity and quality objectivesand performance targets;34• A planning process and strategy to meet thecommitment;• An organized institutional structure to execute thestrategy;• Implementation programs and support tools to meetobjectives;• Communications and training programs; and• Measurement and review process to monitor progress.Figure 1 presents an adaptation of the ISO 14001management tools to a watershed setting.  This adaptionspecially recognizes the institutional and programmaticdimensions of the watershed EMS, especially in thedeveloping world.  The institutional dimension, like theISO standard, addresses the question of whether a set ofinstitutional linkages and specific procedures is in place tomanage  the watershed; and, if so, how effective  they are as  management  tools; and, if not, what institutional linkages and procedures need to be created.  Theprogrammatic dimension, generally uncharacteristic of theISO standard, assesses the adequacy of existingmanagement or regulatory programs (or whether relevantprograms exist at all); and, if they exist, how effective theyare at delivering program goals; and, if they do not exist,what mix of programs needs to be created (borrowingfrom command, financial incentive, pricing, allocation ofuse and access, recharge, pollution prevention, informationmanagement, and other such programs).  Sincecertification need not be a goal (unlike the application ofthe ISO standard to corporations), the standard’s featurescan be adapted, as shown below and in the examples thatfollow, to the needs and legal culture of the jurisdiction inquestion.  If such jurisdiction contains a multiple-usewatershed, care should be exercised  to evaluate it’s  multi-media impacts and whether it requires an integration ofsolutions.35APPLICATIONS OF THE INTEGRATED  EMSDESIGNIn the context of a watershed EMS, the terms “integrated”and “multi-media” have special importance.  An“integrated” EMS combines government interventiontools, such as regulatory/enforcement programs, withmarket-based incentives, including resource and pollutionpricing, to attain environmental goals at least cost tosociety.  A “multi-media” EMS applies these tools acrossall environmental media (air, water, land) to avoidtransfers from one medium to another.  So structured, anintegrated, multi-media  EMS assures that resources areallocated to users based on full information andinternalization of all allocation costs, including concernsfor both quantities of resources consumed and the qualityof those resources.EMSs have been implemented at many levels to solve awide range of environmental management challenges.Single industrial locations have developed EMSs tomanage their environmental performance in water, air, andsolid waste.  Cities have developed EMSs to improve theefficiency and effectiveness of their environmentalprograms or to engage multiple stakeholders in anequitable program of continuous environm entalimprovement.  Regional EMSs have also been successfullyapplied within large industrial or trade zones.Following are two project examples of the application byHagler Bailly of several of the forego ing principles.  Thefirst, as reflected in Exhibit 1, is the special purposedistrict of Laguna Lake Development Authority (LLDA),which oversees the development of, and regulation ofdischarges into, the Laguna de Bay, the largest fresh waterlake in Asia.  The lakeshore is home to countlessindustries, and LLDA was specially created to manage thedevelopment and water pollution control of this uniquemultiple-use watershed whose uses were threatened by alack of effective management, enforcement, andincentives.  Hagler Bailly designed and implemented aprogram that integrated technical, institutional, financial,incentive, legal, and data management elements.  This wasdone through extensive stakeholder meetings, and wasfollowed, in the implementation phase, with an effectivetraining regimen of LLDA staff.  After only the first yearof operation, there was a dramatic decrease in BODcontamination, and the hope of upgrading the water qualityclassification of the lake in the future.  This model isespecially relevant for the management of a regionalwatershed.Exhibit 1: Philippines Special Purpose DistrictEM S Elements ComponentsPolicy Commitment < Program supported by Philippines Department of Natural Resources andLLDA management.Objectives and Targets < Reduce BOD  loadings in Laguna de Bay, the largest freshwater lake in Asia.< If successful, expand reach of the program to other parameters.Planning < Fee system designed to focus on BOD initially, but expandable to otherparameters.< Action plan formulated outlining the procedural documents necessary, abudget, and an implementation timeline.< Extensive stakeholder dialogues.Institutional Structure < Institutional development plan to support the administrative needs of theprogram (fee assessment, permits, billing, collection, appeals process,enforcement, fund management).Implementation andCommunication< Drafted authorizing legislation and operational guidelines for a permit andmonitoring programs.< Capacity building program.< BOD levels reduced 78% in first year of operation.Monitoring and Review < Government is developing plans to apply the EMS nationally.< With continued improvement, LLDA someday hopes to upgrade the lakefrom Class C (non-contact recreation and industrial water supply) to Class Ause (public water supply).36The second project, as reflected in Exhibit 2, addressedthe groundwater problems of an industrial city in Egyptcalled the 10 th of Ramadan.  With twenty percent of itsdrinking water pumped from nearby deep wells, theMunicipal Authority, at our suggestion, found evidence ofheavy metals and other contamination in well samples.Unlined oxidation ponds, capturing liquid industrialwastes from 800 industries, were secretively sluiced to thefields of itinerant farmers to water their crops and theirlivestock.  With extensive stakeholder input, Hagler Baillydesigned a multi-media to tally integrated program thatcombined command and market-based instruments.Borrowing liberally from other management disciplines,such as pollution prevention and the ISO 14000 standards,the program, currently awaiting implementation fundingfrom USAID, features detailed implementing guidelinesfor both government officials and industry managers, andhas been heralded as the most significant environmentalprogram in the Gore-Mubarak Partnership.  It is expectedto be implemented over time in more than 20 industrialcities in Egypt.Exhibit 2: Egyptian Industrial CityEM S Elements ComponentsPolicy Commitment < Pressure to comply with new regulatory requirements (Law 4).< Agreement on EMS memorialized in Memorandum of Agreement (MOA) byMinistries and City’s Board of Trustees (representing industrial investors).Objectives and Targets < Reduction of wastewater discharges.< Elimination of promiscuous dumping of solid waste.Planning < Multi-media coverage: air, water, waste.< Integration of a command system and economic incentives.< Provisions for licensing, monitoring, EIA.< Pollution charge system as a central management tool.< Environmental fund: revenues expected to cover administrative costs andsubsidize environmental investments by industry.< Data management system to store and retrieve compliance-related data.Institutional Structure < Institutional linkages defined and roles and responsibilities fixed.Implementation andCommunication< Extensive advocacy dialogues.< Detailed guidelines for bo th government and  industry.< Implementation at top of Egypt’s environmental agenda.< USAID technical assistance for implementation in late 1999.Monitoring and Review < Government to monitor implementation.< Other industrial cities want this.APPLICATION OF EM S PRINCIPLES TOWATERSHEDSOther applications of the EMS approach are possible,including more geographically expansive watersheds thataccommodate a wide variety of uses.  Common problemsin watershed management include a lack of: authority,enforcement, management know-how, funding, andincentives.  An EMS approach offers distinct advantagesover more traditional watershed planning and managementapproaches with power to deliver measurable, sustainab leresults in:• striking a balance between regulatory and market-driven incentives to change water use and pollutingbehavior;37• capturing value-added in the benefits stream and usingcash flows to offer financial incentives linked tobehavioral change; and• decentralizing the management structure design, withconsensus-based rules of participation and roles forgovernment and private entities.One approach to addressing watershed managementproblems is to implement three pilot EMS structures aimedat different environmental problems in different locations.Pilots will address at least the following critical problemsin water resources management (known in ISO 14001EMS parlance as “objectives and targets”):• Increasing the efficiency of water use, especially in theagricultural and industrial sectors;• Improving the quality of wastewater in the municipaland industrial sectors to support reuse opportunities;and• Attracting private-sector participation in waterresources management.Each EMS pilot could be designed to address specificwater resources problems within a well-defined watershed.The process of designing each EMS pilot will engage allstakeholders within the watershed, which, in turn, helpsensure broad acceptance of problems to be solved,resulting resource management activities, potentialchanges in resource pricing, and new roles andresponsibilities for management.  Typically, a watershed-level EMS results in decentralized institutional roles andlocal actions that cannot be achieved through centralizedapproaches.  The EM S framework is designed to createeconomic incentives for industry, agriculture, and localgovernments to participate in and execute managementactions that cannot be achieved through more traditionalregulatory means.Each pilot EMS might require the preparation of sixproducts that would fit appropriately within the EMSorganizing principles related to planning, support, andimplementation strategies:• Response Model  - A simulation model of waterresources/water quality responses to changes inmanagement activities attributable to the EMS;• Data Managem ent Tools  - Database and/or other datamanagement tools to store, retrieve, and manipulateambient environmental, water use, and discharge data,plus related data elements specific to the EMS andneeded to track and report on environmental outcomesand progress; • Financial Management Mechanisms - Systems,institutions, and/or processes that create or manage theflow of funds from and to stakeholders as conditions ofparticipation in the EMS;• Government Guidelines - A set of detailed instructionsthat specify exact roles and responsibilities for allcentral and local government entities that must executeportions of the EMS during the implementation phase;• Industry Guidelines - A set of detailed instructionsthat specify exactly what private sector participantsmust do to  execute  re levant portions of the EMSduring the implementation phase; and• Mem orandum of Understanding - A legal documentsigned by the cooperating national and localgovernment entities that commits each to  carry out itsresponsibilities as specified in the GovernmentGuidelines.It is likely that the design phase will take 18 months tocomplete, and another 12 to 18 months should be allowedfor implementation.  This allows sufficient time to monitorand measure results, and abstract from each pilotappropriate lessons for purposes of modification of thedesign or application to other watersheds within thesubject jurisdiction.Hagler Bailly argues that it is only through this kind ofcomprehensive application of management principles (thatinclude policy commitment, a planning process, aninstitutional strategy, implementation support tools,communication strategies, and periodic measurement andreview) can decision-makers address seemingly intractablesystemic problems often associated with a multiple usewatershed.38AUTHORSJack J. Schramm,  with Hagler Bailly since 1989 andcurrently senior counsel for environmental management,leads the firm’s international practice in institutional andprogram strengthening.  He has formulated laws andregulations, and developed multi-media integratedprograms and strengthened the institutions that administerthem in 17 countries throughout the world.  A formersenior administrator with the U.S. EnvironmentalProtection Agency, Mr. Schramm holds degrees in politicsand philosophy from Colgate University and in law fromKenneth I. Rubin  is Chief Executive Officer of HaglerBailly Services, Inc., having joined the firm in 1997 as aresult of Hagler Bailly’s acquisition of Apogee Research,Inc., a public works consulting firm that he co-founded in1986 and served as President and CEO.   Dr. Rubin serveson    Hagler   Bailly’s    Executive   and      Management Committees and directs the Water Global Business Sectorfor the firm.  While at the US Congressional BudgetOffice from 1980-1986, Dr. Rubin had responsibility forbudget, finance, and policy research supportingauthorizing, appropriations, and budget committees withjurisdiction over all US water and environmentalinfrastructure agencies including the US Army Corps ofEngineers, the Environmental Protection Agency, and theBureau of Reclamation.  Prior to that at the US WaterResources Council, Dr. Rubin directed a multi-milliontechnical assistance program supporting state watermanagement agencies.  Dr. Rubin holds both a Ph.D. andSM in Water Resources Systems Engineering formHarvard University, an MSPH in EnvironmentalEngineering from the University of North Carolina atChapel Hill, and  a BS in Civil and EnvironmentEngineering from Cornell University.

The Application of Environmental Management System (EMS) Principles to Watershed

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The Application of Environmental Management System (EMS) Principles to Watershed

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