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July 18, 2006

Comments

Dave

I find several weaknesses in the "proposed guide." First, as mentioned in the post, I believe that adaptive management is wrongly framed.

Second, I believe that the alleged NEPA failings are better fixed by following CEQ guidelines for Programmatic to Site-Specific linkups. Suggesting EMS as a White Knight is a bit of a stretch given EMS' track records.

Third, as related to the second concern just above, the guide says (p.4) "The NEPA process generally approaches environmental management decisions on a case-by-case basis, and mainly focuses on identifying and mitigating 'significant' environmental impacts." I would amend the statement by adding the parenthetical words "and wrongly" just before "approaches." So that the statement would read: "The NEPA process generally (and wrongly) approaches environmental management decisions on a case-by-case basis, and mainly focuses on identifying and mitigating 'significant' environmental impacts."

Fourth, the "guide" suggests that "environmental aspects" (e.g. emissions to air, discharges to water) may be considered "cause" in "cause-and-effect relationships involving natural resources." I disagree. I believe that EMS "environmental aspects" might be better thought of as "indicators" of impacts, or "symptoms" of problems. I can't wrap my mind around the idea of environmental aspects as "causes."

Finally, something that isn't necessarily a weakness although it might be—let's call it complexity: Twice on page 2, the guide talks about environmental issues: 1) "… In the EMS context, [environmental aspect] information is used to not only assess environmental issues, but more so, to actively manage them. …", 2) "… Thus, the focus of an EMS is ultimately n the active management of environmental issues …."

The ISO 14001 frames things differently I believe, stating as introduction: "Organizations … are increasingly concerned with achieving and demonstrating sound environmental performance by controlling the impacts of their activities, products and services on the environment…." In the process of managing activities/impact bundles, recognition of "environmental issues" is necessary. So too, ultimately is management of environmental issues. As I understand the ISO 14001, the focus of the EMS is on improving environmental performance of activities/impacts. There is no doubt a linkage to improving the process for managing environmental issues. But it is a focus left more to inference than to explicit process direction in the ISO 14001.

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