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					EUROEMAS Final technical report Annex 7.1




    A step by step guide to managing the implementation of EMAS


                                                      EURO-EMAS
                                              Pan European Local Authority
                                            Eco-Management and Audit Scheme
                                                 (LIFE98 ENV/UK/000605)
                                                      October 2001




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EUROEMAS Final technical report Annex 7.1


                          CITY ……………………………………...

                          UNIT ……………………………………...

                          NAME …………………………………….

                          POSITION ………………………………..

                          DATE …………………………………….

Question 1
For the operational unit within which your city is implementing EMAS, complete the Matrix at the end of this guide. Tick those boxes( )
next to each statement to which you are able to answer ‘yes’ at this moment in time. Complete this matrix each month and develop an
action plan to overcome the barriers you identify.

Question 2
During the last month, upon which step(s) of the EMAS process (e.g. policy, review, programme etc.) have your efforts to implement
EMAS concentrated?


                       STEP                                       TICK

Policy                                                                 
Review                                                                 
Programme                                                              
Management System                                                      
Audit Planning                                                         
Audit                                                                  
Statement                                                              
Validation                                                             
Implementation                                                         




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EUROEMAS Final technical report Annex 7.1




Question 3
In relation to the step(s) upon which your efforts to implement EMAS have concentrated during the last month and with reference to the
EMAS Matrix, describe the progress that you have made.


         STEP                                                                PROGRESS




                                                            Continue on separate sheet if necessary




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EUROEMAS Final technical report Annex 7.1



Question 4
In relation to the step(s) upon which your efforts to implement EMAS have concentrated during the last month, describe any barriers to
progress that you have encountered and any actions taken to overcome these barriers.


         STEP                                                      BARRIERS AND ACTIONS




                                                            Continue on separate sheet if necessary




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EUROEMAS Final technical report Annex 7.1




Question 5
In relation to the barriers to progress that you may have encountered, what assistance f do you require to overcome the barriers?


         STEP                               BARRIER                                               ASSISTANCE




                                                      Continue   on separate sheet if necessary




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EUROEMAS Final technical report Annex 7.1



EMAS Matrix

                                      1                                                       2                                                3
  LEVEL                             POLICY                                                 REVIEW                                          PROGRAMME

                  Formal corporate environmental policy                 Complete register of all significant direct and     Complete implementation of environmental
      3          adopted and its objectives fulfilled               service environmental effects of operational            action programme within operational unit         
                  Policy fully integrated within other policy          unit                                                 Demonstrated commitment to continuous
                 areas                                                  Regular review mechanisms across operational       environmental improvement within the unit 
                  Clear budgetary provisions                          unit ensuring register update                        Action or proposed action to meet all
                                                                         Formal register of statutory environmental                                                          
                  Regular policy review mechanism                                                                          significant effects identified in register
                                                                        obligations applicable to operational unit           Performance monitoring mechanisms
                                                                                                                             implemented                                      
                  Formal environmental policy adopted               Draft register of all significant direct and           Incomplete implementation of action
                  Policy only partially integrated within other        service effects of operational unit which requires   programme within operational unit                
      2          policy areas                                          greater analysis                                     Commitment to continuous environmental
                  Resource commitments met from existing                Incomplete mechanisms for recording unit’s         improvement within the unit                      
                 budgetary provisions                                  environmental effects                                Action to meet some of the significant effects
                                                                         Draft register of statutory environmental                                                           
                  Irregular policy review mechanism                                                                        identified in the register
                                                                        obligations applicable to operational unit           Objectives, targets, responsibilities and
                                                                                                                             monitoring mechanisms determined                 
                  Informal or draft environmental policy only       Informal records of unit’s significant direct          Draft environmental action programme
                  Policy inconsistent with other policy areas      and service environmental effects                      complete                                         
      1           Absence of resource commitments to back               No mechanism for recording changing                 Proposed commitment to continuous
                 policy                                                environmental effects                               environmental improvement within the unit 
                  No policy review mechanism                           Informal records of unit’s statutory                Proposed action to meet all of the significant
                                                                        environmental obligations                           effects identified in the register               
                                                                                                                              Objectives, targets, responsibilities and
                                                                                                                             monitoring mechanisms not determined             
                  No environmental policy approved at                   Limited awareness of unit’s environmental        No environmental action programme for the
      0          corporate level                                       effects and statutory responsibilities           operational unit                            




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EUROEMAS Final technical report Annex 7.1



EMAS Matrix (Continued 1)

                               4                                                    5                                    6
  LEVEL                LANAFEMENT SYSTEM                                     AUDIT PLANNING                            ATDIT


                 Formal schedule for audit circulated              Audit report complete and circulated to top
      3         throughout the operational unit              local government managers                            

                 Formal appointment of independent auditors 

                 Members of audit team sufficiently skilled and
               independent                                    
Environmdnta
l Lanafelent
M`nual fully
implemented
within
operational
unit

 Unit’s
personnel
have
completed a
environmental
training
programme

 Mechanisms
for recording
environmental
actions in
place and
results
documented



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EUROEMAS Final technical report Annex 7.1




 Individual
responsibilitie
s fully
integrated
within job
descriptions

                   Formal ‘Environmental Management Manual’                                                              Formal assessment of compliance of
                  specifying roles, responsibilities and resources     Formal schedule for audit of operational unit   operational unit with corporate environmental
      2            Formal environmental training programme for        devised                                          policy complete                                 
                  unit’s personnel                                                                                       Formal assessment of monitoring of objectives
                   Formal mechanisms for recording                     Audit team with appropriate skills and          and targets as set out in environmental
                  environmental actions                               independence identified                          programme complete                              
                   Formal identification of individual                                                                   Formal assessment of roles, responsibilities
                                                                                                                         and resources as set out in Environmental
                  responsibilities                                 
                                                                                                                         Management Manual complete                      
                   Informal documentation specifying roles,            Informal schedule for audit of operational unit  Formal assessment of compliance of
      1           responsibilities and resources                      only                                             operational unit with corporate environmental
                   Limited and ad-hoc environmental training for                                                        policy underway                                 
                  unit’s personnel                                     Independence of audit team open to question     Formal assessment of monitoring of
                   Informal mechanism for recording                                                                     objectives/ targets as set out in environmental
                  environmental actions                                Appropriate skill requirements of members of    programme underway                              
                   Informal identification of individual              audit team unclear                                Formal assessment of roles, responsibilities
                                                                                                                         and resources as set out in Environmental
                  responsibilities                              
                                                                                                                         Management Manual underway                      
                    No specified environmental roles,                  No planning undertaken within the operational  No audit undertaken                             
      0           responsibilities, and resources within the           unit in preparation for audit                   
                  operational unit                              
Appendix 1: EURO-EMAS Matrix (Continued 2)

                                      7                                                   8                                              9
  LEVEL                           STATEMENT                                          VALIDATION                                    IMPLEMENTATION



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EUROEMAS Final technical report Annex 7.1



                    Formal statement in the wake of audit                   Accredited environmental verifier’s report             Corrective action identified by validation
       3           available to the public                              complete                                               report informing plans for next cycle                     
                    Formal statement in the wake of                                                                                 Corrective action identified by audit report
                   environmental review available to the public                                                                    informing plans for next cycle                         


                    Formal statement in the wake of audit                   Validation process conducted by accredited             Corrective action identified by validation
                   complete                                                environmental verifier complete                        report has been fully implemented within
       2            Formal statement in the wake of                                                                                operational unit                                       
                   environmental review complete                                                                                    Corrective action identified by audit report
                                                                                                                                    fully implemented within operational unit              

                    Draft statement in the wake of audit                Validation process conducted by accredited                Corrective action identified by validation
                    Draft statement in the wake of the                     environmental verifier underway                     report has been partially implemented within
       1           environmental review                                                                                            operational unit                                       
                    Informal consultation procedure on the                                                                          Corrective action identified by audit report
                   documents contents                                                                                              partially implemented within operational unit      

                    No public environmental statement of the                No validation process                              No implementation of corrective active
                   operational unit                                                                                                identified by audit or validation process          
       0




BARRIERS
Introduction

Sections 5.4 to 5.9 identified a number of barriers to the implementation of EMAS in European Municipalities.

They have been categorised as four scenarios presenting barriers to the implementation of EMAS. Awareness of these barriers will enable prospective municipalities to identify potential
barriers and focus their efforts to overcoming them.

Scenario I: Partner cities are experiencing barriers to progress that arise from the universal complex practicalities of implementing EMAS.




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EUROEMAS Final technical report Annex 7.1


This scenario assumes that the partner cities are struggling with the technicalities of EMAS. In particular, barriers to progress arise during each of the seven steps of the
EMAS process.

Step 1: Environmental Policy
Barriers may result from problems with:
 structures for public consultation
 establishing agreement over aims and principles of action
writing a policy that conforms to EMAS requirements.

Step 2: Environmental Review
Barriers may result from problems with:
 identifying significant effects
 distinguishing between direct and service effects
 determining legal and regulatory constraints
 putting in place a set of indicators to quantify significant effects
 devising an appropriate format for a register of significant effects.

Step 3: Environmental Programme
Barriers may result from problems with:
 obtaining agreement over objectives
 identifying those one-off and continuing actions that will be undertaken to reduce significant environmental effects
 identifying actions within existing institutional structures. For instance, purchasing actions may have a significant effect on the environmental performance of an
operational unit, but control and responsibility for purchasing issues may not lie with the operational unit themselves.
 specifying indicators to monitor the success of each action
 setting a realistic target for the improvements in performance generated by each action
 agreeing timetables and deadlines for each action
 identifying those members of staff responsible for each action
 availability and allocation of time and resources for each action

Step 4: Environmental Management System
Barriers may result from problems with:
 identifying individuals responsible for decision-making, information collection, and monitoring
 putting in place recognised procedures for decision-making, information collection and monitoring, including mechanisms for recording
 establishing a management system in a written format


Step 5: Environmental Audit
Barriers may result from problems with:
   explaining the requirements of EMAS to internal auditors.

Step 6: Environmental Statement
Barriers may result from problems with:



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EUROEMAS Final technical report Annex 7.1


 ensuring that the statement corresponds with the aims and principles of action laid out in the environmental policy
 determining the format and length of the statement
 deciding the ‘depth’ of information provided in the statement
 putting in place appropriate mechanisms to ensure that the statement is effectively disseminated to the public

EXAMPLES OF SCENARIO I

 The City of Birmingham
Many of the Environmental and Consumer Services Department’s buildings are shared with other departments and organisations. Many of the buildings are old and the
metering systems do not correspond to the areas of the building used. Complicating this further is the lack of formal arrangements for measuring resource use. Often
such tasks are not identified within job descriptions and even if they are, they might not be enforced. This makes measuring, monitoring and reporting on resource use
for the department very difficult. Financial resource is a big issue here.

 The City of Palermo
Barriers to progress during the implementation of the Environmental Review step have been identified in terms of identifying and measuring significant indirect effects.
Palermo has selected the Planning Department as the operational unit within which EMAS will be implemented, with a particular focus on the renewal of the City Plan.
Issues concerning significant indirect effects are inherent to the application of EMAS to this set of activities.

 The City of Göteborg
Barriers to progress during the implementation of the Environmental Programme step have been experienced. The environmental review of the District Committee of
Askim identified purchasing policies as a key set of activities contributing to significant direct effects. Putting in place an Environmental Programme has, therefore,
entailed the development of green purchasing policies.

SCENARIO II: Partner cities are experiencing barriers to progress that arise from attempting to implement LA-EMAS, as developed in the UK, in diverse local
and national contexts.

This scenario assumes that barriers to progress arise from a range of ‘mismatches’ between the LA-EMAS model developed in the UK on the one hand, and diverse
local and national contexts of the partner cities on the other. In particular, barriers arise from differences in language, experience, tradition, geography, and institutions.

 Language
Many of the technical terms employed by the UK LA-EMAS model may simply not have an equivalent term in the national languages of the partner cities. Alternatively,
technical terms may have an equivalent that implies a different meaning. As such, the specifics of the UK LA-EMAS model may be lost in translation.

 Experience
The UK LA-EMAS model is able to assume a common base line of experience in the environment for all UK cities. Such a baseline may conflict with the varying levels
of experience in the environment across the partner cities in the EURO-EMAS project. The partner cities may be ‘below’ of ‘above’ the UK baseline.

 Tradition
The UK LA-EMAS model is able to assume a common national environmental tradition that provides the legislative and policy-making framework for EMAS. Given that
EMAS constitutes a self-regulatory initiative, the UK’s legislative and policy-making tradition may be particularly conducive to encouraging the up-take of EMAS. In
contrast, the partner cities of the EURO-EMAS project encompass a range of national traditions that may or may not be conducive to EMAS.

 Geography


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EUROEMAS Final technical report Annex 7.1


The UK LA-EMAS model is able to assume a broadly common geography and climate. Partner cities in the EURO-EMAS project may have specific geographical and
climate concerns that the UK LA-EMAS model does not necessarily address. For instance, existing work on environmental auditing and management systems by the
Union of Baltic Cities sought to develop a model to meet the specific environmental needs of cities in the Baltic region.

 Institutions
The UK LA-EMAS model is able to assume a common institutional framework at both national- and city-level for the implementation of ELAS. In contrast, the partner
chties hn the EURO-DM@S projebt h`vd ` vide r`nfe of diverse institutional frameworks within which they are seeking to implement EMAS. Institutional differences from
the UK, for instance in terms of relationships between national, regional and city levels and within city administrations themselves, may lead to specific barriers to the
implementation of the UK LA-EMAS model.

EXAMPLES OF SCENARIO II

 The City of Leipzig
Barriers to progress arising from language have been experienced. Personnel within the Municipal Park’s Gardening Department do not speak English. Translation
requirements to assist training within the Department have not been sufficiently prioritised.

 The City of Stockholm
Somewhat paradoxically, barriers to progress have arisen due to the extensive experience of the City of Stockholm in environmental management. Stockholm has
already developed its own environmental management system and, as such, is well ‘above’ the baseline of experience assumed by UK LA-EMAS. UK LA-EMAS,
therefore, appears to have little to offer the City of Stockholm,

 The Cities of Athens and Leipzig
Similar barriers to progress have been encountered in the Cities of Athens and Leipzig arising from institutional factors. Neither Athens or Leipzig have city institutions
within which the leadership of the EMAS process can be easily incorporated into their functions. As a consequence, both Athens and Leipzig are employing private
consultants to oversee the implementation of EMAS in their city’s respective operational units.

Scenario III: Partner cities are experiencing barriers to progress that arise from an incapacity to gain local political support for the objectives of the project.

This scenario assumes that the major barrier to progress in the implementation of EMAS is political. Representatives of partner cities may have signed-up to the project
without prior local political support for EMAS broadly and the objectives of the project in particular. Alternatively, previous political support for EMAS and the EURO-
EMAS project may have been undercut by electoral results. An incapacity to gain local political support tends to manifest itself in the following problems:

 an inability to complete the environmental policy step of the EMAS process. UK LA-EMAS requires that environmental policy is written for the local government as a
whole (i.e. a corporate document). This necessarily requires that the policy is approved at the highest political levels within the local authority since it must eventually be
implemented throughout the local authority.

   insufficient resource flows to back the EMAS process.
   on-going delays in the implementation of all steps of the EMAS process.
   Lack of environmental specialists, officers with knowledge, interest or commitment (this is mainly due to it not being perceived as important but also due to
    budgetary limitations)
   Lack of officers with time to spend on the side of the section that is the subject of the EMAS implementation, it is seen as an extra task and this creates pressure
    and problems




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EUROEMAS Final technical report Annex 7.1


   Unsureness and lack of understanding of the potential benefits of an EMS. Detailed information about financial savings could sell EMAS much better at a senior
    officer or political level.

EXAMPLES OF SCENARIO III

 The Cities of Athens, and Leipzig
The Cities of Athens and Leipzig have both encountered barriers to progress arising from an incapacity to gain local political support. Both Cities have, therefore, been
unable to-date to produce a corporate Environmental Policy document and have experienced periodic and on-going delays in the implementation of the EMAS process.

 The City of Birmingham
Birmingham’s Environmental & Consumer Services Department has also encountered barriers to progress arising from the need to approve the Environmental Policy at
Departmental level. As with Athens and Leipzig, this has taken a very long time to produce and was significantly affected by a departmental merger of large scale which
forced further analysis of the appropriateness of the content nf the Pnlicx document. Howevdr, tnlije Athdnr `nd Leipzig, the implementation of the Review, Programme,
Management System and Statement steps of the EMAS process has proceeded well in Birmingham.

 The City of Newcastle
The City of Newcastle had experienced problems in gaining full political support for EMAS. In particular, this has manifested itself in an inability to review and revise an
existing Environmental Policy document that was outmoded and outdated. This has now been updated and has full approval.

 The City of Stockholm
Electoral processes led to a change in the political leadership in the City of Stockholm. Political backing for EMAS has been rendered uncertain, leading to periodic
delays in the work of implementing the EMAS steps.

 The City of Bologna
Local political support for the EURO-EMAS project in the City of Bologna was not secured at the outset of the project. As a consequence of the acute barriers to
progress that subsequently arose, the City of Bologna withdrew from the project.

SCENARIO IV: Partner cities are experiencing barriers to progress that arise from an incapacity to institutionalise responsibility for the implementation of
EMAS.

This scenario assumes that barriers to progress in the implementation of EMAS are, in the main, a result of a poorly defined structure of responsibility. In short,
‘ownership’ of the EURO-EMAS project has not been effectively established within the partner cities. In particular, a poorly defined structure of responsibility may
emerge because of the following:

 responsibility for environmental matters broadly may not be determined
 existing responsibilities of members of staff may conflict with EMAS
 previous environmental auditing and management initiatives may generate a stronger sense of ownership
 clear lines of communication may be difficult to establish within a structure of responsibility. For instance, a member of a partner city’s LA 21 team may be leading the
implementation EMAS, but his/her relationship with the members of the operational unit within which EMAS is actually being implemented may be unclear.

5.3.9    EXAMPLES OF SCENARIO IV

 The Cities of Athens and Leipzig


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EUROEMAS Final technical report Annex 7.1


Barriers to progress have been encountered in both Athens and Leipzig as a consequence of the absence of clearly defined institutional responsibilities for
environmental matters. For further details, see also Scenario II.

 The City of Stockholm
Barriers to progress have been encountered in Stockholm as a consequence of a strong sense of ownership of the City’s own environmental management system.
Establishing and institutionalising responsibility for EMAS has proved problematic.

 The City of Helsinki
Barriers to progress have been encountered in Helsinki due to problems with establishing clear lines of communication within the City. Overall responsibility for the
coordination of the EMAS process was with one person, who was also responsible for LA21. This person only had time for one project, not both, and as LA21 is more
important in the City, having more influence and commitment, EMAS was delayed.
PWD resources for the EMAS project have been small. Other projects have got more interest and publicity. The lack of available information has caused problems in
progressing each division within PWD. The problems are compounded due to lack of commitment and technical problems with resources.




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