رتبه بندی جنبه های زیست محیطی در سیستم های مدیریت زیست محیطی : روش جدید تست شده بر روی مقامات محلی

A new method is described to determine and to rank the significance of the environmental aspects of a local authority, as a basis for the implementation of an environmental management system (EMS). The method is especially important as for the requirements of the EU “Environmental Management and Audit Scheme” (EMAS), a standard open to all sectors including public authorities. The method has been applied to the Municipalities of Faenza (a large town with 54,000 inhabitants) and of the small towns of Riolo Terme, Brisighella, Casola Valsenio (RA, Italy), which obtained or are on the way to get the EMAS certification.

In 2001, the European Union (EU) extended the Eco-Management and Audit Scheme (EMAS), which was originally intended for companies to evaluate, report and improve their environmental performance, to all economic sectors including public and private services. In particular, local councils at the Municipality level can enter the certification process (Clausen et al., 2002). Since this revision (European Community, 2001/761 and European Community, 196/2006), nicknamed EMAS-II, many local authorities in Italy and Europe have started to develop environmental management systems, as a tool for making the organization more environmentally proactive and efficient (Emilsson and Hjelm, 2002). Today the public administration sector is one of the fastest growing sectors as regards to EMAS implementation (European Commission — DG Environment website, 2008). A third revision of the EMAS regulation has been agreed by the Council and the European Parliament on April 2, 2009 and will probably be adopted by the end of 2009; it won't carry forwards relevant changes in the evaluation of significance, but it will introduce important novelties in the use of indicators. The purpose of this paper is to introduce a new method for assessing the significance of environmental aspects, based on principles of transparency and consistency. The proposed method is clear, well defined and reproducible. It has been defined so that it takes into account both environmental issues and management ones. This method is particularly recommended for local authorities because it offers a good assortment of choices in the evaluation of the control exerted on the environmental aspects, often share with other public or private institutions. Moreover, the proposed method is structured according to the principles of “expert systems”, which already include a knowledge-base and can therefore be used by people not expert in the specific domain; in this case, the “environmental knowledge” is already embedded in the method itself and therefore is not required from the users. Although the method has been defined for and tested with local authorities, it could be easily applied in other contexts. 1.1. Environmental management systems An environmental management system (EMS) includes the environmental dimension within the management structure and is aimed at improving the environmental performance of the organization; it is a method of incorporating environmental care throughout the corporate structure (Perotto et al., 2008). In a continuous process, organizations commit themselves to evaluate their environmental impact and to set targets for improvement. Various EMS, particularly the EMAS regulation and the ISO14001 scheme (International Standard Organization, ISO 14001, 1996/2004) are based on the plan-do-check-act (PDCA) methodology (Ridolfi et al., 2008, Vazzana et al., 2004, Deming, 1986 and Marazza, 2007). The PDCA cycle is known as Deming cycle, from the industry consultant W. Edwards Deming who proposed it for continuous improvement of total quality management (UNC-Chapel Hill, 2003). Through the repetition of the cycle, the EMS is to achieve continuous improvement over time, which is a basic concept for all management systems. The PDCA cycle can be summarized as follows: – P (PLAN): plan activities according to priorities, define policies, goals, targets, rules; – D (DO): implement the planning under the chosen rules; – C (CHECK): verify the results; – A (ACT): review priorities, goals, targets and, in case, policies and rules. 1.2. EMS in local authorities Local authorities present some unique features that have to be considered when structuring an EMS suitable for them (Lozano and Vallés, 2007): – Local authorities have a considerable number of different duties: schools, waste disposal, road maintenance, law enforcement, planning, fire brigade, procurement, leisure and many more. The indirect aspects often prevail over the direct ones, and their assessment is a complex and tedious matter, which may call for intense considerations and professional help from consultants and universities (Ridolfi et al., 2008, European Commission, 2008 and Lozano and Vallés, 2007). It is not always easy to classify an aspect as direct or indirect, for there are many cases of shared responsibility. – Local authorities act over a whole territory, not only on their own premises; they have an important institutional role on environmental communication, and have the possibility to address the companies located in the area towards some sustainability commitment (Casale, 2005). – The stakeholders are not limited to clients, providers or neighbours, but include the whole community living in the territory administered by the authority. Moreover, while the clients of a company can change their providers if they are not satisfied with the product, the people living in a Municipality can choose, by voting, the ruling party, but have little other possibilities, apart from moving somewhere else, if they are not satisfied with the administration. – While a local authority can attain continuous improvement of its environmental performance just as a private company, there are some differences as to the obtainable benefits, which usually are long-term and spread out to the whole community in terms of economical, environmental and social consequences. – The motivations for developing an EMS in a local administration often imply the desire to set an example for other organizations and to have a positive outcome in the territory (Clausen et al., 2002). – Concerning Municipalities, a large majority have a small number of inhabitants (in Italy, 72% have less than 5000 inhab. (ISTAT, 2001)). It can be easily inferred that these Municipalities also have a small number of employees (probably under 10 people). This very likely implies a lack in environmental professionals and in scientific skills. As remarked in the Introduction, the public administration sector is one of the fastest growing sectors as regards to EMAS application. The above considerations, together with this growing trend and the high number of local authorities in Europe suggest that a method for assessing environmental significance specifically tailored on the needs of Municipalities could be very useful and be broadly diffused. 1.3. Environmental aspects A very important step in order to implement an EMS is the setting of priorities in order to plan the improvement activities. Therefore, the organization has to identify its environmental aspects and assess their significance through the environmental management system. Article 3.1 of Annex I-A of the EMAS regulation states that: “The organization shall establish, implement and maintain a procedure(s) a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and b) to determine those aspects that have or can have significant impact(s) on the environment (i.e. significant environmental aspects). The organization shall document this information and keep it up to date.” It is therefore crucial to define criteria, thresholds and categories in order to provide a reference scale for the significance. According to the EMAS-II regulation, an environmental aspect is an element of an organization's activities, products or services that can interact with the environment. A specific activity ‘a’, managed by the organization, can generate one or more environmental aspects ‘e’ (e.g. emissions, wastes, energy or matter consumption), generating in turn one or more impacts ‘i’ in the environmental domains (atmosphere, biosphere, hydrosphere and lithosphere): ai→eij→iijkai→eij→iijk Turn MathJax on where the indices refers to the activity (i), the environmental aspect (j), and the impact (k). As an example, the heating of the buildings of the organization (activity) generates fuel consumption and emissions into the atmosphere (aspects), which affect public health and the standing stock of natural resources (impacts). The EMAS-II regulation distinguishes between direct and indirect environmental aspects. The former are defined as those over which the organization has management control; the latter as aspects over which it may not have full management control or that involve other parties. Both kinds should be evaluated in normal, start-up, shut-down and emergency conditions. The Annex VI of the Regulation lists some examples of direct and indirect aspects. Direct aspects may include emissions to air, releases to water, avoidance, recycling, reuse, transportation and disposal of solid and other wastes, particularly hazardous wastes, use and contamination of land, use of natural resources and raw materials (including energy), local issues (noise, vibration, odour, dust, visual appearance, etc.), transport issues (both for goods and services and for employees), risks of environmental accidents and impacts arising, or likely to arise, as consequences of incidents, accidents and potential emergency situations. Indirect aspects may include product-related issues (design, development, packaging, transportation, use and waste recovery/disposal), capital investments, granting loans and insurance services, new markets, choice and composition of services (e.g. transport or the catering trade), administrative and planning decisions, product range compositions, the environmental performance and practices of contractors, subcontractors and suppliers. If the organization willing to implement an EMS is a public administration, the distinction between direct and indirect aspects may not be easy to assess (EURO-EMAS, 2001). This problem, and a proposed solution, will be discussed in this paper. 1.4. Significance Annex VI of the EMAS-II Regulation states that “An organization shall consider all environmental aspects of its activities, products and services and decide, on the basis of criteria taking into account the Community legislation, which of its environmental aspects have a significant impact, as a basis for setting its environmental objectives and targets.” It is the responsibility of the organization to define the criteria. The Regulation adds some details on how to establish these criteria: they shall be comprehensive, capable of independent checking, reproducible and made publicly available; considerations should include appraisal of the environmental conditions, existing data, views of stakeholders, regulations, procurement, products' life cycle, environmental costs and benefits. The EMAS-II regulation gives no further indication on how to perform the significance evaluation of the environmental aspects, even if it is recognized as an essential point of an environmental management system (Darbra et al., 2005, Gernuks et al., 2007, Ghisellini and Thurston, 2005, Johnston et al., 2000, Parker, 1997, Perotto, 2006, Põder, 2007, Zobel et al., 2002 and Zobel and Burman, 2004). Zobel (2008) depicts the situation by saying that the criteria to be fulfilled and verified are stated, but the means for satisfying them are not. Many authors underline this lack of orientation (Darbra et al., 2005, Ghisellini and Thurston, 2005, Johnston et al., 2000 and Perotto, 2006) and recognize the need for research in this field (Zobel and Burman, 2004) and the importance of achieving transparency, reproducibility and a certain grade of objectivity (Perotto, 2006, Põder, 2007 and Zobel et al., 2002) in an activity believed to be one of the most difficult stages in implementing an EMS (Darbra et al., 2005, Hillary, 1998 and Lundberg et al., 2007). Objectivity is intended as the ability to get a true representation of reality, and could be measured by the reproducibility of the results of the significance evaluation obtained by different people. Once the significant environmental aspects have been identified by the organization, they become part of the environmental improvement programme: the EMAS Regulation states that the organization shall ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system. The non-significance aspects will be reassessed in a further cycle of the EMS. 1.5. Assessing the significance of environmental aspects Assessing the significance of environmental aspects usually involves ranking them through the use of categories, values and thresholds. Commission recommendation 2001/680/EC (2001) suggests that “the criteria selected can be taken as questions to be answered with ‘yes’ or ‘no’, or they can be used in a more differentiated way”. Due to the lack of guidance in the EMAS Regulation on how to evaluate the significance of environmental aspects, a lot of methods have been proposed in literature, manuals, handbooks and technical books. For example, the European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL) produced a “Doing the right things II — Step-by-step guidance book for planning of environmental inspection”. The handbook addresses risk assessment issues which are similar to the identification and ranking of environmental aspects, and collects a number of good practices. The authors state that “to give a limitative list of all the risk criteria that we can assess is not possible. Every inspecting authority will define its own risk criteria”. Risk is defined here in a broad sense: it includes any factor an authority wants to take into account when assigning priorities. It may be an environmental risk, a social or economic risk, a compliance risk etc. (IMPEL, 2008). The use of some form of scale to screen and classify each effect is widely used (Hillary and Loth, 1998). However, many of the existing methodologies have flaws due to lack of quantitative evaluations, excessive simplification and subjectivity in the score assignment and choice of criteria (Perotto, 2006). Some authors have conducted a review of the methods proposed so far (Perotto, 2005, Põder, 2007, Zobel and Burman, 2004 and Darbra et al., 2005). Põder (2007) recognizes inconsistencies and limited transparency and reproducibility as a common shortcoming for many organizations implementing EMS. He conducted a study on 22 Estonian companies and classified their methodologies in two main categories: those considering only the severity and probability criteria, a basic approach in risk assessment, and those taking into account several dimensions, including socio-economic variables. The author finds that the first category provides much flexibility of usage, but it can also result in limited reproducibility; the methodologies which combine more variables provide a framework for systematic and orderly thinking, but they can have shortfalls due to vaguely defined or overlapping criteria, apart from requiring considerable effort and know-how (Darbra et al., 2004). The methods appreciated for their flexibility and simplicity of usage are also criticized for their limited reproducibility due to subjectivity and use of personal judgement (Perotto, 2006). According to Põder (2007), it is crucial to include, explicitly or implicitly, all basic dimensions influencing the outcome, for the assessment not to be inconsistent and to avoid overlapping. The author proposes a three tiered decision scheme that could facilitate the evaluation process, taking into account predefined conditions like the violation of legally established conditions, the severity of the aspect, its probability, socio-economic factors and uncertainty. Zobel and Burman (2004) stress the importance of reproducibility, which is necessary for the credibility of the entire management system. They list some of the most commonly suggested criteria in literature: the scale of the impact, the severity of the impact, the probability of occurrence, the permanence of impact, the actual or potential regulatory/legal exposure, the difficulty of changing the impact and the concerns of stakeholders. They find a clear distinction between authors that only suggest environmental concerns when assessing the aspects and those that also suggest business concerns. The authors also conducted a study on 46 Swedish companies and concluded that it is possible to classify their methods for assessing the significance of environmental aspects in some categories, according to the presence of a specific tool and its reference to traditional risk assessment or Life Cycle Assessment (LCA). They also refer to another classification proposed by Woodside et al. (1998): available assessment methods can be divided into three different approaches: consideration of selected documented criteria without any weighing factors, consideration of selected documented criteria with weighing factors and judgement by environmental professionals. Ghisellini and Thurston (2005) carried out a survey on the cognitive decision traps into which companies may fall during implementation of EMS, and remark that the methods used in evaluating the aspects' significance may be based on an inadequate set of criteria that do not accurately identify the real significance of the aspects. They also acknowledge the existence of brainstorming procedures for assessing the significance of environmental aspects, which do not imply formal scoring. Another widely used criterion is the compliance with the law, which, according to Dias-Sardinha and Reijners (2001), is the most common environmental strategic objective of organizations.

The measurement of the environmental significance in a EMS entails a review of the environmental problems connected to the management conditions. The application of the proposed method results in an ordered list of environmental priorities, which is obtained considering both the management and the environmental importance of the aspects. A high significance resulting from this analysis does not express a negative evaluation; on the contrary, it indicates an aspect which could be greatly improved by a change in the environmental policy of the organization. The assessment of the significance of an aspect could be summed up by a Boolean expression: a full competency AND a totally unfitting strategy AND a serious environmental problem give the maximum of significance; a null competency OR a total fitting strategy gives a null significance. The efficacy of an EMS implemented by a local authority should be evaluated by the decrease in the number of high significance environmental aspects. This can be proposed as one indicator of the efficacy of the EMS, and according to Commission recommendation 2003/532/EC (2003) it can be classified as a “Management Performance Indicator — MPI”. In particular, the EMS should be implemented keeping a “zero G principle” in mind: a high number of “zero G” cases indicate an effective internal organizational structure capable of planning, executing, checking and reviewing a defined environmental strategy. It also indicates high knowledge content in the organization and trained personnel. In one sense, the “zero G principle” is the driving force towards continuous improvement of the administration in the EMAS scheme. This paper refers in particular to local authorities, the government level closest to the citizen, whose participation in EMS implementation throughout Europe has a positive influence on the environmental habits of the general public and can contribute to the implementation of the principles of sustainable development at local level.