PUR 316

Environmental Impact Assessment and Environmental Audit

(City Campus)
Lecturer: Dr. Leah Onyango

Topic 7
Mitigation

Approaches to Mitigation
Depending on the timing of the project cycle and the nature of impacts, a number of approaches
can be taken to achieve the objectives of mitigation.
These include:
 developing environmentally better alternatives to the proposal;
 making changes to project planning and design;
 carrying out impact monitoring and management; and
 compensating for impacts by
o monetary payment
o in kind measures
o site remediation bonds
o a resettlement plan.

‘Mitigation’ refers to the process of avoiding or reducing adverse impact or enhancing the
environment into which a project is being placed. After the identification and evaluation of
impacts it is a fundamental objective of EIA to highlight measures that mitigate the unavoidable
adverse consequences.

In general a number of mitigating strategies can be adopted. These are:

 Avoidance
 Reduction/remediation;
 Compensation for impacts; and
 Enhancement;

Avoidance
Avoidance of impacts through careful siting and design is the most effective mitigation strategy.
Where alternatives are available, the selection of the option that avoids sensitive receptors can
save time and money during the design and assessment process.

Reduction
Reducing adverse environmental effects is the next mitigation strategy that should be considered.
Reduction of impacts by design measures including:
 Bounding and screening to mitigate noise and visual impacts;
 Tunnels through road embankments to mitigate the impacts on migrating animal
movement; and
 Technological solutions such as flue gas desulphurization can mitigate air quality
impacts.
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The way in which the development is operated and managed can mitigate potentially adverse
impacts. Examples are:
 Restricting the working hours of noisy operations;
 Washing vehicles to reduce the spread of mud and dust from construction sites;
 Covering newly filled areas of landfill with inert wastes to prevent problems with odours,
windblown litter, gulls and rodents.

Remediation
Correcting or curing the adverse effect on the receptor is a possible mitigation strategy. It differs
from ‘Reduction’ in that the effect at the receptor is the focus of the work rather than the source
of the impact.

Good working practice can help to reduce impacts considerably. E.g. Noise impact may be
reduced by fitting silencers to plants creating the noise; and remediated by supplying double-
glazing to inhabitants of property affected by the noise.

Compensation for Impact

In some cases it may be possible to offset adverse impacts by related environmental
improvements. Many people however, question whether true compensation is ever possible, and
this approach should only be considered as a last resort. (E.g. mitigation of GHGs by creating
sinks)

Enhancement
The development of a project may also provide opportunities to enhance the environment into
which it is being placed, particularly where the existing environment is considered to have been
degraded.

Type of mitigation How it works Examples

measure
Prevention & Fully or partially prevent an Prevent contamination of wells,
Control measures impact/reduce a risk by: by:
Changing means or technique Siting wells a minimum distance
Changing the site from latrines.
Specifying operating practices Operate wastewater treatment
system for a coffee- washing
station.
Compensatory Offset adverse impacts impacts in Plant trees in a new location to
measures one area with improvements compensate for clearing a
elsewhere construction site.
Remediation Repair or restore the environment Re-grade and replant a borrow pit
measures after damage is done. after construction is finished

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ENVIRONMENTAL MANAGEMENT PLAN (EMP)
An environmental management plan (EMP), also referred to as an impact management plan, is
usually prepared as part of EIA reporting. It translates recommended mitigation and monitoring
measures into specific actions that will be carried out by the proponent. Depending upon
particular requirements, the plan may be included in, or appended to, the EIA report or may be a
separate document. The EMP will need to be adjusted to the terms and conditions specified in
any project approval. It will then form the basis for
impact management during project construction and operation.

The main components of an EMP are described in Box 1, which reflects practice at the World
Bank. Although there is no standard format, the EMP should contain the following:
• summary of the potential impacts of the proposal;
• description of the recommended mitigation measures;
• statement of their compliance with relevant standards;
• allocation of resources and responsibilities for plan implementation;
• schedule of the actions to be taken;
• programme for surveillance, monitoring and auditing; and
• contingency plan when impacts are greater than expected.

Box 1: Components of an environmental management plan (EMP)

The following aspects should typically be addressed within an EMP:
• Summary of impacts: The predicted adverse environmental and social impacts for which
mitigation is required should be identified and briefly summarised. C referencing to the EA
report or other documentation is recommended.
• Description of mitigation measures: Each mitigation measure should be briefly described
with reference to the impact to which it relates and the conditions under which it is
required (for example, continuously or in the event of contingencies). These should be
accompanied by, or referenced to, project design and operating procedures which elaborate
on the technical aspects of implementing the various measures.
• Description of monitoring programme: The monitoring program should clearly indicate
the linkages between impacts identified in the EIA report, measurement indicators,
detection limits (where appropriate), and definition of thresholds that will signal the need
for corrective actions.
• Institutional arrangements: Responsibilities for mitigation and monitoring should be
clearly defined, including arrangements for co-ordination between the various actors
responsible for mitigation
• Implementation schedule and reporting procedures: The timing, frequency and
duration of mitigation measure should be specified in an implementation schedule,
showing links with overall project implementation. Procedures to provide information on
the progress and results of mitigation and monitoring measures should also be clearly
specified.
• Cost estimates and sources of funds: These should be specified for both the initial
investment and recurring expenses for implementing all measures contained in the EMP,
integrated into the total project costs, and factored into loan negotiations
Source: World Bank, 1999

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The EMP should contain commitments that are binding on the proponent. It can be translated
into project documentation and provide the basis for a legal contract that sets out the
responsibilities of the proponent. In turn, the proponent can use the EMP to establish
environmental performance standards and requirements for those carrying out the works or
providing supplies. An EMP can also be used to prepare an environmental management system
for the operational phase of the project.

CARRYING OUT IMPACT MONITORING AND MANAGEMENT

Mitigation measures are implemented as part of impact management. This process is
accompanied by monitoring to check that impacts are ‘as predicted’ When unforeseen impacts or
problems occur, they can require corrective action to keep them within acceptable levels, thereby
changing the mitigation measures recommended in an EIA or set out in an environmental
management report.

Mitigation and monitoring are a critical part of environmentally sound design:

 Mitigation minimizes adverse environmental impacts
 Monitoring tells you if your mitigation measures are sufficient & effective.

Monitoring: analysis and dissemination:

 Analysis is an essential element of monitoring - raw or unprocessed environmental data is
not useful to decision makers or project managers
 Dissemination of monitoring results is critical

SUMMARY
The purpose of mitigation is to:
• find better ways of doing things
• enhance environmental and social benefits
• avoid, minimise or remedy adverse impacts
• ensure that residual impacts are within acceptable levels.

The purpose of impact management is to:

• ensure mitigation measures are implemented
• establish systems and procedures for this purpose
• monitor the effectiveness of mitigation measures
• take action when unforeseen impacts occur.

Proponents have a responsibility to:

• avoid, minimise and remedy adverse impacts
• internalise the environmental and social costs of the proposal
• prepare plans for managing impacts
• repair or make restitution for environmental damages.

A framework for impact mitigation

Principles of mitigation
• give preference to avoid and prevent measures
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• consider feasible alternatives to the proposal
• identify customised measures to minimise each major impact
• ensure they are appropriate and cost-effective
• use compensation as a last resort.

Impact avoidance can be achieved by:

• not undertaking certain projects or elements
• avoiding environmentally sensitive areas
• use of measures to prevent impacts from occurring
– site remediation bonds
– resettlement plans
– in kind measures and offsets

Impact minimisation can be achieved by:

• scaling down or relocating the proposal
• redesigning elements of the project
• measures to manage the impacts.

Impact compensation can be achieved by:

• rehabilitation of resource or environmental components
• restoration of the site to its previous state
• replacement of the environmental values lost at another location.

Mitigation options
• develop alternatives that are better environmentally
• make changes in planning and design
• carry out impact monitoring and management
• compensate for residual impacts
 monetary payment
 site remediation bonds
 resettlement plans
 in kind measures and offsets

Environmental management plans should contain a:

 summary of impacts
 recommended mitigation measures
 statement of compliance with standards
 allocation of resources and responsibilities
 schedule of required actions
 surveillance, monitoring and auditing programmes
 contingency measures for greater than expected impacts

Environmental Impact Mitigation

The mitigation of impacts must be considered whether or not the impacts are significant
Mitigation can be defined as:
 Avoiding the impact altogether by not taking a certain action or parts of an action.
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 Minimizing impacts by limiting the degree or magnitude of the action and its
implementation.
 Rectifying the impact by repairing, rehabilitating, or restoring the affected environment.
 Reducing or eliminating the impact over time by preservation and maintenance operations
during the life of the action.
 Compensating for the impact by replacing or providing substitute resources or environments.

Mitigation: Avoid --> Minimize --> Repair or Restore --> Reduce over time --> Compensate

This ordered approach to mitigation is known as "sequencing" and involves understanding the
affected environment and assessing transportation effects throughout project development.
Effective mitigation starts at the beginning of the EIA process, not at the end. Mitigation must be
included as an integral part of the alternatives development and analysis process.

Environmental mitigation activities means “strategies, policies, programs, actions, and activities
that, over time, will serve to avoid, minimize, or compensate for (by replacing or providing
substitute resources) the impacts to or disruption of elements of the human and natural
environment associated with the implementation of a long-range state wide transportation plan or
metropolitan transportation plan.

The human and natural environment includes, for example, neighborhoods and communities,
homes and businesses, cultural resources, parks and recreation areas, wetlands and water sources,
forested and other natural areas, agricultural areas, endangered and threatened species, and the
ambient air.

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