EMAS در مقامات محلی : شاخص های مناسب در اتخاذ سیستم های مدیریت زیست محیطی

In the context of new tools suitable for making local authorities more pro-active in terms of effectiveness in environmental management, this paper analyzes the case of the application of EMAS (Eco-Management and Audit Scheme) to local authorities in Italy. EMAS is a European tool that was revised in 2009 with Regulation (EC) N. 1221/2009, named EMAS III. This paper has two goals. The first goal is to analyze how the local authorities, with an environmental management system registered under EMAS, evaluate the environmental aspects related to their activities. The second goal is to propose a set of specific indicators to be monitored, which would fulfill the EMAS III compulsory core-set of indicators. To do this all the EMAS registered public authorities in Italy have been contacted to obtain a copy of their most recent validated environmental statements. Then, for each environmental aspect considered, a matrix has been processed, reporting on related activities, environmental significance, indicators, and environmental targets to improve the performance of the EMS. The analysed environmental statements (75% response rate) deal with a high number of environmental aspects and refer to a wide range of activities carried out by the local authorities. The set of indicators demonstrates that registered local authorities have already enough information for the purpose of complying with the new EMAS III core indicators. On the contrary, EMAS III does not properly cover the several environmental issues and impacts faced by local authorities, so that a different, wider and more specific framework is needed for their environmental performance evaluation. As a result of this study, a set of 13 indicators has been proposed, based on those already in use by local authorities and on those used by the European Environment Agency for environmental assessments. Therefore, this paper can represent a first step towards the definition of sectorial reference guidelines that will be developed at the European level by the European Commission.

A considerable number of new tools are now available for the purpose of making local authorities more environmentally pro-active and effective. Among them are the strategic environmental assessment (European Directive 2001/42/EC; European Commission, 2001a), environmental impact assessment (85/337/EEC; European Commission, 1985), life cycle assessment (LCA), and standardized environmental management systems (EMSs). ISO 14001 is the dominant international reference for assessing environmental management processes, while in Europe many companies are also registering their EMSs according to the Eco-Management and Audit Scheme (EMAS, Regulation (EC) N. 761/2001 (European Commission, 2001b)), which was updated in 2009 with the introduction of Regulation (EC) N. 1221/2009, named EMAS III (European Commission, 2009). An EMS of an organization is broadly defined as a transparent, systematic corporate-wide process, with the purpose of prescribing and implementing environmental goals, policies, and responsibilities, as well as regular auditing of its elements (Steger, 2000). Standardized EMSs can provide organizations with relevant information about the state of the environment and improve the structure of environmental work. In addition, EMSs can assist the decision-making process by the use of suitable indicators that helps the monitoring program carried out in the organization (Emilsson and Hjelm, 2002). The first aim of this paper is to analyze how local authorities, with an EMS registered under EMAS, have addressed the evaluation of the environmental aspects related to their activities. The second aim is to investigate whether the new core-set of indicators, introduced by EMAS III, can be fulfilled by using the old set of indicators. Whenever this is not possible, we propose a set of alternative more specific indicators to be monitored, taking into account both EMAS III requirements and the list of related indicators already tested by the European Environment Agency to monitor the different environmental aspects. The paper is organized as follows: in Section 1.1 the international standard ISO 14001 and the European standard EMAS are briefly described and compared in terms of requirements and applications. Section 1.2 describes the different suitable indicators for the implementation of an EMS according to EMAS requirements. The implementation of EMAS in the public sector, in particular for local authorities, is reported in Section 1.3. In Section 2 the local authorities involved and the materials and methods are detailed. Results are illustrated and discussed in Section 3, while the main conclusions are found in Section 4. 1.1. ISO 14001 and EMAS The two main reference schemes for EMS design and certification are the international standard ISO 14001 and the European standard EMAS (Eco-Management and Audit Scheme). ISO 14001 provides guidelines by which corporations or other organizations design and implement an EMS that supports (Jackson, 1997): (1) their environmental policy; (2) the environmental aspects related to their activities; and (3) their environmental management programs with a clear structure of responsibility for environmental management. ISO 14001 is based on a Deming Cycle (or PDCA cycle) with four steps (Langley et al., 2009): the “Plan” step consists of the planning of actions to achieve the improved management goals; the “Do” step implements the change decided during the plan phase; the “Check” step verifies whether the goals have been achieved and, if not, during the “Act” step the planning is reviewed and the cycle re-starts. Through the reiteration of this cycle, the EMS can achieve a continuous improvement over time, which is a basic idea behind this standard (Marazza et al., 2010). The Eco-Management and Audit Scheme (EMAS) is similar to ISO 14001 in its components and requirements (Morrow and Rondinelli, 2002 and Ridolfi et al., 2008). EMAS was introduced in 1993 with the EC Regulation N. 1836. After its revision in 2001 (EMAS II, EC Regulation N. 761) EMAS widened its scope to all types of organizations and it entirely adopted ISO 14001 requirements for EMS implementation (European Commission, 2010a). Important distinctions between the two standards still remain. EMAS is more rigorous than ISO 14001 in the analysis of environmental aspects and requires organizations to issue an environmental statement with the aim of providing validated information to the public. Furthermore, during the registration phase, the organization is subject to an “institutional” control by a National Competent Body. Recently, the third revision of this standard, called EMAS III, was published by the European Commission as Regulation N. 1221 (European Commission, 2009). EMAS III introduces some novelties in terms of core performance indicators, and environmental aspects that must be taken into account, such as energy efficiency, water use, waste production, air pollution and biodiversity. During the past decade, the diffusion of EMAS in Europe has increased, reaching 7709 sites and 4507 organizations by June 2010 (European Commission, 2010b). Among the European member countries, the highest number of registrations is still held by Germany (1408), followed by Spain (1227) and Italy (1035) (Fig. 1). The basis for the application of an EMS to an organization is the environmental review of its activities. Therefore, the organization has to identify and quantify the environmental aspects related to its activities, products or services, which it can control (direct aspects), and those over which it can have only an influence (indirect aspects). In this sense, EMAS Regulation provides a specific list of direct environmental aspects that must be taken into account in the review, and must be related to each activity carried out by the organization (European Commission, 2009): • emissions to air; • releases to water; • waste production and management; • use and contamination of land; • use of natural resources, energy and raw materials (including additives, auxiliaries and semi-manufactured goods); • local issues (noise, vibration, odour, dust, visual appearance, etc.); • transport issues (both for goods and services and employees); • possible environmental risks related to incidents, accidents and potential emergency situations, and • effects on biodiversity. Each aspect must be described by specific indicators in order to allow the organization to assess their environmental significance in terms of environmental impact. For each significant environmental aspect the organization must define adequate objectives for improvement to be achieved through an environmental programme. This programme describes responsibilities, means and deadlines. The progress must be monitored and measured on a regular basis through documented procedures. 1.2. Suitable indicators for the implementation of an EMS under EMAS In the context of EMAS, decision-makers, the public and all the possible readers of environmental statements should easily understand the environmental indicators (Kurtz et al., 2001). This requirement is explicitly highlighted by the European Commission Recommendation 2001/680/EC (European Commission, 2001c). The identification of appropriate indicators is, therefore, a crucial task. For this purpose a good reference is the international standard ISO 14031 (ISO, 1999), which gives guidance on the design and use of indicators suitable for EMAS. This standard classifies environmental indicators in three main categories: ECI (environmental conditions indicators), MPI (management performance indicators) and OPI (operational performance indicators) (ISO, 1999). Recently, the importance of OPI in EMS implementation has been further outlined by EMAS III, which asks all registered organizations to monitor and report yearly on the following nine core indicators (European Commission, 2010c): (i1) total annual energy consumption (in MWh or GJ); (i2) percentage of total annual consumption of energy (for electricity and heating) produced by the organization from renewable energy sources; (i3) annual mass-flow of different materials used (excluding energy carriers and water) (in tons); (i4) total annual water consumption (in m3); (i5) total annual production of waste, for each typology (in tons); (i6) total annual production of hazardous waste (in kilograms or tons); (i7) use of land (in m2 of built-up area); (i8) total annual emission of greenhouse gases, including at least the emissions of the following pollutants: CO2, CH4, N2O, HFCs, PFCs and SF6 (in ton CO2 equivalent); (i9) total annual air pollution, including at least the emissions of SO2, NOx and PM (in kilograms or tons). In order to ensure comparability of the information from different reporting periods and among different organizations, EMAS III requires industrial organizations to refer each core indicator to: total annual gross added value or total annual turnover, total annual physical output (in tons), and number of employees. For all the other sectors, including local authorities, the core indicators have to be related only to the number of employees or the number of inhabitants. All organizations that intend to keep their EMAS registration will need to report on the above core indicators. Therefore, organizations will also have to evaluate if these indicators are really suitable for describing and managing their environmental performance issues. This task is especially relevant for non industrial organizations because the compulsory set of indicators is mainly focused on environmental aspects related to production. However, EMAS III refers to future sectorial reference guidelines that will be developed by the European Commission, providing a set of environmental indicators applicable to specific sectors: this objective opens an interesting research field to the scientific community, which could provide useful inputs for this purpose. 1.3. The implementation of EMAS in local authorities The awareness of the strong linkages among humans and environment is recognized. It is common to refer to these systems as socio-ecological systems (Liu et al., 2007, Petrosillo et al., 2006 and Zurlini and Girardin, 2008). In this context, social actors are increasingly required to be involved in decision-making processes concerning environmental management, giving relevance to the contribution they can provide in affecting the sustainable development in a positive way (Petrosillo et al., 2007). This kind of management is defined as “adaptive management” and is based on a learning-by-doing approach (Holling, 1978 and Gunderson and Holling, 2002). This perspective represents a similarity with EMAS tool, where the aim of the environmental management system is the continuous improvement of the environmental performance of an organization, i.e. local authority. In the framework of adaptive management, local authorities are recognized as key players in local development (Zotos et al., 2009) as well as in the case of EMAS. Local authorities are the institutional level closer to citizens; therefore they have an important influence on the environmental habits of residents and can make a major contribution to the implementation of the principles of sustainable development at the local level. At the same time, local authorities can play a relevant role in terms of environmental pressures produced by their everyday decisions. This because they have a number of different duties, which can influence the “quality of life” of citizens, i.e., waste management, integrated water services, transport, road maintenance, and many other more (Ridolfi et al., 2008, Lozano and Vallés, 2007 and Quaglino et al., 2010). The application of a tool like EMAS to a local authority can have beneficial environmental effects on the entire territory (Lozano and Vallés, 2007). These benefits can be noticed even outside the domain of the local authorities. The EMAS environmental statement is a public annual report that can improve the external image as well as the environmental reliability of the local authority through the use of international eco-compatible procedures (Botta and Comoglio, 2007). In addition, this report is a way for local authorities to encourage the private bodies acting in the area towards sustainability commitments, in compliance with the general principles of pollution prevention and environmental protection. These aspects explain why the implementation of registered EMS is gaining the attention of an increasing number of municipalities. Among the over 4000 EMAS registered organizations, the most frequent sector is the “General public administration activities”, NACE code 84.11, with 268 organizations, mainly located in Italy (157) and Spain (87) as of June 2010 (European Commission, 2010d). In addition, this standard provides managerial and organizational tools for carrying out the institutional planning and operational activities, directing the decision-makers’ attention towards sustainable development and environmental protection (Emilsson and Hjelm, 2002). For these reasons the EMS implementation should be based on reliable and representative indicators, which enable local authority to evaluate, monitor and improve its environmental performances. The selection of an adequate set of indicators is more challenging for local authorities than for private companies because the environmental aspects are often indirect, i.e. not under their full management control (Emilsson and Hjelm, 2007). For example, the use of water resources and energy can be easily monitored and improved when related to the local authority buildings, infrastructures and activities, while limited control and influence can be exerted over other users within the municipal boundaries. In the same way, the behaviour of citizens regarding reducing and separating waste strongly affects the efficiency and performance of the urban waste collection system. Since indirect aspects can be more significant than those related to the organizational structure, EMAS requires local authorities to address them adequately (European Commission, 2001d and European Commission, 2009).

The European Government imposes environmental regulations by setting qualitative or quantitative limits on different environmental issues or by requiring the adoption of specific abatement technologies. Such an approach, called “command-and-control”, has been criticized because it has been demonstrated that it is difficult to manage, inflexible, and cost-ineffective (Arimura et al., 2008). This approach is based on a simplification of environmental issues, which may be successful in the short-term but the negative effects of long-term consequences may often outweigh short-term benefits (Pahl-Wostl, 2007). As already highlighted by Ludwig et al. (1993) in the case of fisheries management, thinking of resources managing humans is more appropriate than the contrary. Therefore, the control of environmental problems is an illusion, while more emphasis is given to the idea of adaptive management (Holling, 1978, Pahl-Wostl, 1995, Pahl-Wostl, 2002 and Lee, 1999). Adaptive management is based on the insight that the ability to predict future key drivers as well as system behaviour and responses are inherently limited. Specifically for this reason, the basic concept behind adaptive management is “learning by doing”, where decision-makers need to learn from the past to avoid future mistakes. Adaptive management seems to have several similarities with the voluntary standards (ISO 14001 and EMAS), based on the continuous improvement of management in terms of environmental performances. These standards, introduced at European level to spread a pro-active environmental approach, do not represent an alternative to environmental prescriptive mandates or economic instruments, i.e., pollution taxes and emissions trading. Rather, they should be seen in an integrated way with environmental regulations, also because, as highlighted by Arimura et al. (2011), the scientific findings about the effectiveness of voluntary action adoption are equivocal. The extension of voluntary procedures to local authorities represents an additional step forward in the field of pro-active management approach. In this context the use of EMS according to EMAS and the identification of environmental performance indicators suitable for local authorities are essential, because they can be of help in managing and quantifying the effects of management choices (Niemeijer and de Groot, 2008).