To ensure that environmental impacts are identified and appropriately managed, information on relevant stakeholders, their needs and possible contribution to the project should be collated and documented.
To ensure that environmental issues are appropriately managed, project environmental responsibilities and communication requirements must be identified and documented.
To ensure that where appropriate environmental challenges are met within the procurement process, including through life contracts management and performance.
The main objectives of this procedure are the identification, documentation and maintenance of:
- Stakeholders and their requirements and contribution;
- Project environmental responsibilities;
- Communication requirements.
A further objective is the assembly of the Environmental Committee.
2.2.1. Step 1: Identify Stakeholders, their Requirements and Information Available
Stakeholders include individuals/groups that:
- Include the Equipment Capability Sponsor and the User;
- May be given responsibility for the project in later stages of CADMID or CADMIT (e.g. other Project Teams, Disposal Services Authority etc.);
- Have a regulatory role or function (MOD internal and external) in relation to the deployment and use of the capability being acquired;
- Have environmental requirements from the project (e.g. Defence Infrastructure Organisation may need information to complete site specific environmental assessments);
- Have responsibilities regarding the procurement process (i.e. have the ability to embed environmental considerations into design and through life contract management);
- Hold relevant environmental information to the project or related systems or platforms (e.g. other Project Teams, Front Line Commands, Defence Infrastructure Organisation);
- Have environmental concerns regarding the project (e.g. other Government Departments, pressure groups, the general public);
- Are part of MOD and have an assurance role for equipment and capability acquisition projects.
When identifying stakeholders, consideration should be given to stakeholders relevant to each life cycle stage of the project.
Form EMP02/F/01 - Register of Stakeholder Requirements and Information shall be completed by recording stakeholders’ environmental concerns, requirements and/or any relevant environmental information they may hold. Contact details for stakeholders shall be recorded.
Note that for projects where the Product System or Service is likely to receive considerable interest from the general public or external organisations (e.g. regarding noise issues), that it may not be possible at this stage to accurately establish either the degree of concern, the number of people concerned, the requirements for information or relevant contact details. However, this should not prevent the Project Team from recording them as a stakeholder as this information can be gathered later in the project where necessary. Recording such external groups at this stage does not mean that they will be contacted or actively engaged with at any stage merely that their concerns can be accounted for.
2.2.2. Step 2: Produce Communications Plan
A Communication Plan (see GMP02) should be formulated which identifies the need, timing, purpose and appropriate method(s) for stakeholder consultation. This can form part of the Safety and Environmental Plan. The Communication Plan should include contact details, information requirements, lines of communication, frequency and media of communication, responsibilities and any relevant security considerations.
Where pertinent the communications plan shall cover acquisition requirements setting along with end users and suppliers. It can be beneficial to provide communications focus at key points within the procurement process ranging from early engagement and advertisement through to contract management and performance.
Where the communications plan is expanded to include the procurement process, this should be reflected within the sustainable procurement plan.
The requirement for a communications plan should be relevant and proportional to the project. A communications plan is required for all projects undertaking an EIM assessment. If a Communication Plan is not appropriate for the project, the Project Team should record the justification for this decision in the Safety and Environmental Management Plan.
Initially, stakeholders identified for consultation at this stage will be internal to the MOD. However, any relevant external stakeholders identified (e.g. Other Government Departments, regulatory bodies, suppliers etc.) should be logged and included in the Communication Plan even if no communications are currently planned.
It is not a requirement of POEMS to contact every stakeholder. For example, where the project may provoke considerable public interest the risk this may cause to the project may be sufficiently managed by producing relevant objectives and targets (see Procedure EMP06 – (Setting Objectives and Targets)) without engaging in consultation. However, the Project Team has responsibility to decide the best way to manage stakeholder concerns taking into account the likely impact of the Freedom of Information Act and the Environmental Information Regulations and the MOD presumption of openness.
2.2.3. Step 3: Stakeholder Agreements: Define and Agree Project Environmental Responsibilities
Environmental responsibilities in relation to the project must be clearly defined and agreed with the relevant internal and external stakeholders. This includes the designation of a member of the Project Team who will be responsible for environmental issues related to the project throughout its whole life cycle.
Other environmental responsibilities shall be assigned and documented if possible at this stage, including the responsibility for carrying out any downstream studies. Downstream studies include sustainability appraisal for projects to be utilized on Defence Infrastructure Organisation property, or for providing information to stakeholders e.g. MOD POEMS documentation may be required for systems to be used on the Army Training Estate.
Responsibility for the maintenance of all documents and records produced as part of the Environmental Management System, and applying for permits and authorisations should also be assigned and documented.
Form EMP02/F/02 - Project Environmental Responsibilities, should be used for recording these responsibilities. In deciding on roles and responsibilities, consideration should be given to any opportunities for the project to be grouped with other similar projects.
Responsibility shall be assigned for maintaining communications as required.
2.2.4. Step 4: Stakeholder Agreements: Assemble Environmental Committee
The Environmental Committee shall be assembled for the project.
The members of the Committee should include representatives of the main MOD stakeholders and those having particular expertise relevant to the equipment or service being acquired, e.g. Subject Matter Experts. Members of the Committee external to MOD may comprise industry or scientific experts, consultants or academics that can provide advice to the Project Team on environmental issues related to the project.
The members and Terms of Reference of the Environmental Committee should be documented. All individual responsibilities of members of the Environmental Committee should still be recorded in Form EMP02/F/02.
A formal record of Environmental Committee meetings including actions should be appropriately documented and retained as an element of the Environmental Case.
The Project Team Leader is responsible for ensuring adequate resources are dedicated to the management of safety and environmental protection within their area of responsibility, and for facilitating appropriate arrangements to discharge responsibilities relating to this procedure in an efficient and effective manner.
Responsibility for ensuring those arrangements are implemented, and achieve outputs which fully satisfy legislative and departmental requirements for safety and environmental protection (including compliance with this procedure), shall be formally delegated in writing to a named, competent individual within the team.
2.4.1. Initial Application
For new projects this procedure should be undertaken as early as possible in the Concept Stage, prior to Initial Gate approval
The outputs of this procedure will require periodic review and possible revision throughout the lifetime of the project. The appropriate timings for such reviews will be determined through following Procedure EMP09 – Continuous Review.
2.4.3. Required Outputs
Conformance should be demonstrated by completing one of the following required outputs:
- Completed Form EMP02/F/01 – Register of Stakeholder Requirements and Information;
- Completed Form EMP02/F/02 – Project Environmental Responsibilities;
- Environmental Committee assembled and Terms of Reference agreed;
- Communication Plan (also refer to SSP01 – Communication)
2.4.4. Records and Project Documentation
A copy of the information produced from following this procedure shall be added to and inform the project’s Environmental Case.
2.4.5. Aligning Safety and Environment
The key alignment opportunity of this EMP is to establish combined Safety and Environmental Committees.
2.4.6. Legacy Systems
When applying this procedure to legacy systems the following questions should be asked.
- What is the remaining length of time of the equipment’s or service’s projected service life?
- Are there future plans for major modifications and capability enhancements involving stakeholders as yet not involved, and if so when?
- Is there historic evidence of actual environmental incidents and impacts, if so when, where and what?
- Has there been any stakeholder (particularly external to MOD) interest to date (for example Parliamentary Questions or enquiries regarding the equipment’s environmental performance)?
Considering these questions should ensure that the outputs from this procedure for legacy systems are neither over-engineered nor incomplete. For many legacy systems, with limited life, it will be appropriate to concentrate on disposal arrangements and impacts (especially where there is no evidence of environmental incidents or accidents associated with the in-service phase of the system’s life cycle). The outcome of the screening and scoping procedure should reflect this.
2.4.7. Warnings and Potential Project Risks
If this procedure is not completed, and reviewed (see Procedure EMP09 – Continuous Review) in a timely manner there will be delays in engaging stakeholders and establishing effective environmental management arrangements. Any short comings in this could compromise Initial Gate or Main Gate procedures and approvals and result in costly reworks, especially where opportunities to influence design and procurement decisions are missed.
2.5. Version Control
2.5.1. Version 2.3 to 3.0 uplift
2.5.2. Version 3.0 to 3.2 uplift
The following changes have been introduced in this version:
- New paragraph 2.1.3 - (SP Tool Release) Sustainable Procurement (SP) Content
- Additional SP content added paras 126.96.36.199 to .5 (Communications Plan)
- Addtional Environmental content added to para 188.8.131.52 following T45 test.
Further details can be found in the POEMS Transition document.
2.5.3. Version 3.2 to 3.3 Uplift
Minor text changes to align with ASP taxonomy.