This procedure represents the first step of the Environmental Impact Management (EIM) process which will assist project teams to manage their medium and high environmental priorities.
6.2. Procedural Overview
Medium and high environmental priorities and other important factors assessed during previous EMPs shall be assigned targets and objectives in order to reduce or eliminate the environmental impacts of the project.
This procedure directs the formulation of appropriate objectives and targets to reduce those impacts which:
- Are recognised as important in the context of continued capability or resilience;
- Have been evaluated as medium or high priority; or
- Enhance any potential benefits.
Low priority impacts should be addressed where these can be easily eliminated or mitigated. For information, guidance on these terms based on the ISO 14001 standard, are included below:
- Objective - An “overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve”;
- Target - A “detailed performance requirement, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives”.
Objectives and targets are vital in helping to maintain environmental performance and drive continuous improvement. Once objectives and targets have been developed, they will inform, and be documented within, the Environmental Management Plan (EMP) (EMP01 - Environmental Management Plan).
6.3. The Procedure
Targets shall be devised once a finalised list of objectives has been developed.
Each objective shall be examined separately and a target (or multiple targets) set to act as criteria against which performance is measured.
Targets shall be “SMART”; Specific, Measurable, Achievable, Realistic and Time-bound. Targets can be expressed in many ways including percentages and total quantities or in terms of a regulatory threshold or specific actions.
The development of Key Performance Indicators (KPIs) may be required to show that an objective and target has been achieved. Where used, KPIs must be recorded.
The Environmental Management Plan shall be the means through which the objectives and targets are achieved.
6.3.1. Step 1: Group Priority Environmental Aspects and Impacts
To facilitate objective and target development, medium and high priority environmental aspects and impacts should be grouped where it is known that improvement in one area would bring about improvement in another. This will ensure that repetition or overlaps in objectives and targets are minimised.
6.3.2. Step 2: Set Objectives and Targets
In addition, consideration must also be given to developing objectives and targets to ensure that the project conforms to any environmental standards identified in Procedure EMP03 - Standards Identification, and to ensure that no deterioration in environmental performance occurs. Consideration of stakeholder concerns can also be part of objective and target setting, particularly for projects where there may be considerable interest from the general public or environmental pressure groups.
Objectives and targets may be set which span a project’s life cycle from Concept through to Disposal. However, Project Teams should be aware that objectives and/or targets can be set which only apply to particular stages of CADMID/T. Once set, objectives and targets shall be reviewed and revised when necessary throughout the lifetime of the project. For example, objectives and/or targets may require amendment in response to changes in project design or environmental legislation. Following Procedure EMP09 – Continuous Review, will ensure they are reviewed when required.
Considerable consultation with stakeholders and/or research may be required to assess the feasibility of objectives and/or targets associated with a project. For example, if the completion of this procedure is carried out by the project supplier or contractor, any suggested objectives and targets produced must be referred to and agreed by the Project Team with advice from the Environmental Committee.
Additionally, consideration can be given to incorporating environmental objectives and targets within contract performance criteria. Embedding environmental considerations within the procurement process will require careful consideration and require the involvement of appropriate stakeholders.
The table below gives some examples of areas where objectives and targets could be developed. Note that there may be more than one target for each objective.
To reduce the amount of hazardous materials contained in the project.
Reduce the amount of lead used in manufacturing the equipment by 10% by December 2020.
To reduce noise emissions from the system.
Reduce system’s engine noise emissions by 3dB(A) within 3 years. Reschedule aircraft maintenance activities that involve the running of aero engines in or near residential areas by the end of the year to avoid the hours between 2200 and 0700.
To improve fluid containment to reduce risk of leakages and spills.
Ensure that all staff involved in fuel dispensing are trained in best practice spillage protection measures by end of June 2018.
When formulating and prioritising objectives and targets, consideration should be given to MOD policy, corporate risk and:
- Embedding environmental issues within the procurement process;
- Priority of environmental impact;
- Applicable legislation and standards;
- Ease of implementation;
- Financial implications;
- Operations implementation;
- Disposal implications;
- Safety implications;
- Technological options;
- Project timescales;
- Stakeholder requirements and interests.
The reasons why objectives and targets have been formulated must be clearly documented in case justification is required in the future.
If an objective and target has not been produced for a medium or high priority environmental impact justification for this must be clearly documented.
6.3.3. Step 3: Document Objectives and Targets
Firstly, enter the environmental impact, standard requirement (including legislation and policies) or stakeholder concern you are aiming to manage into the first column of Form EMP06/F/02 - Environmental Objective and Target Register. For environmental impacts, this information should be taken from Form EMP04/F/01 – Environmental Feature Matrix (output from Procedures EMP04 and EMP05) and for standard requirements and stakeholder concerns, captured in Forms EMP02/F/01 and EMP02/F/02. Next, transfer the identified objectives and targets from completed Form EMP06/F/01 to Form EMP06/F/02 and assign a reference for each.
6.3.4. Step 4: Develop the Environmental Management Plan
- Designation of responsibility for achieving objectives and targets at each relevant function and level of the organisation;
- The means and time-frame by which they are to be achieved.
The plan should be reviewed for new activities, significant changes and long-term projects. Progress against the objectives and targets set must be reviewed periodically using Procedure EMP09 – Continuous Review.
6.3.5. Step 5: Verification
It is appropriate for objectives and targets to be developed by a Working Group, Committee or a body of SQEP. The Project Team Leader will accept the objectives and targets when included in the Environmental Case Report by endorsing the report.
The Project Team Leader is accountable for environmental objectives and targets.
The Project Team Leader may delegate to internal focal point(s) and subsequently to external advisors where specialist knowledge is not available internally.
CAD - Concept Stage, Assessment Stage or Demonstration Stage and reviewed as the project progresses.
MID/T - If the project has already passed Concept, Assessment or Demonstration stages, appropriate and proportional work must be conducted in the current project stage. PTs should not be overly concerned if detailed information upon which to base the objectives and targets is not available at the earlier stages of the project’s life cycle. Objectives and targets may be initially based on reasonable assumptions and estimates and then reviewed and amended, as and when necessary, throughout the lifetime of the project (for example, when further information becomes available). Once the objectives and targets are produced, an Environmental Management Plan for achieving them can be developed which should follow the whole life cycle of the project.
The outputs of this procedure will require periodic review and revision throughout the lifetime of the project. This is relevant where objectives or targets have been set early within the project for later life cycle stages. The appropriate timings for such reviews will be determined through following Procedure EMP09 - Continuous Review.
6.6. Required Inputs
6.7. Required Outputs
Conformance with the standard should be demonstrated by completing the following required outputs:
6.7.1. Records and Project Documentation
EMP07 will incorporate the outputs from EMP06 into the Environmental Case Report or similar documentation, which is stored in the Environmental Case.
Additionally, objectives and targets will be retained within the EMP.
6.8. Further Guidance
Environmental management guidance can be found in the following publications:
- DSA01.1 Defence Policy for Health, Safety and Environmental Protection;
- JSP 418 Management of Environmental Protection in Defence;
- DSA02-DMR MOD Shipping Regulations for Safety and Environmental Protection;
- JSP454 Land Systems Safety and Environmental Protection;
- JSP518 Regulation of the Naval Nuclear Propulsion Programme;
- JSP520 Safety and environmental management of ordnance, munitions and explosives over the equipment acquisition cycle.
It may be possible to obtain existing environmental reports and studies from suppliers and manufacturers operating in the same technology areas or which produce similar and related equipment or services.
6.8.1. Aligning Safety and Environment
The key alignment opportunity in EMP06 is to ensure that environmental objectives and targets and related safety objectives and targets are consistent and compatible, and where possible are achieved by the same action.
6.8.2. Legacy Systems
In all cases it will be important to ensure that all applicable legislative and other requirements have been identified and to confirm that all appropriate mitigation measures have been identified. For many legacy systems, with limited life, it can be appropriate to concentrate on disposal arrangements and impacts especially where there is no evidence of environmental incidents or accidents associated with the system.
An Environmental Impact Statement should be produced in all cases, even if it is possible to limit the extent and scope of the environmental assessment process for a legacy system.