A Strategy for Integrating NEPA with EMS

and IS0 14000

Charles H. Eccleston
It is vital that federal managers consider new approachesfor enhancing environmental protection while reducing redundanciesand cost. Faced with increasing environmental issues, compliance requirements, competing resources, and tightened budget constraints, agencies must seek
innovative approaches for doing more with less. The diverse array of confusing and sometimes
inappropriate or conflicting regulatory requirements compounds compliance complexities and
increases the need to seek resourceful solutions.
At a time when NEPA is coming under closer congressional scrutiny, an integrated NEPNEMS
paradigm provides a keyfor increasing the effectivenessand uniformity of imp1ementingNEPAat
the early planning stage, while reducing cost, delays, and redundancies. Effectively integrated,
NEPA satisfies one of the five, and perhaps most important, principles of an EMS-environmental
planning. NEPH's regulatory requirements not only are consistent with the objective of an EMS,
but actually enhance the effectiveness of an EMS. An integrated approach provides the added
benefit of increased environmental coordination and heightened communications that translates intofurther cost reduction and fewer delays. The strategy described in this article is designed
to balance the rigors of an international standard with the need to efficiently implement an integrated NEPNEMS system, given a diverse set of challengingcircumstancesand constraints.
Defore exploring a new approach to environmental management, let us first stop
and ask what processionary caterpillars
may have in common with federal planning and environmental compliance. As
some of you may already know,
processionary caterpillars worm their way
through tree branches, with their heads fitted snugly against the rear extremity of
their predecessor, so as to form a long
winding procession. Hence the aptly deserved designation-processionary caterpillars.
Intrigued by this behavior, the naturalist Jean-Henri Fabre lured a colony of these
creatures onto the rim of a pot. In due time,
the caterpillars began to snuggle up to one
another, eventually forming an intercon-

CCC 1088-1913/98/070309-09
8 1998John Wiley & Sons. Inc

nected chain that started moving around in

a large circle. Having no beginning or end,
Fabre expected that the caterpillars would
soon tire of this unceasing parade and head
off in a new direction. Such was not the
case, Fascinated, Fabre placed a supply of
food next to the processing circle, but to no
avail. The food supply was outside the
domain of their circle. To his dismay, the
caterpillars continued on. Propelled by
sheer force of habit, the living circle kept
edging on in an unceasing circle for six
days and nights. Finally, exhaustion and
starvation did them in. They were unable
to break convention and venture beyond
their established paradigm.
Today, federal agencies increasingly
are being asked to do more with less. Effi-

ENVIRONMENTALQUALITY MANAGEMENT / Spring 1998 / 9

Yet, NFPXs
effectivenessas a
planning tool often
is diminished
because it either has
not been properly
applied or integrated
into agency
planning.

ciency is vital to the success of achieving

an agencys organic mission. So as not to
go the way of the processionary caterpillars, agencies must be open to new and
more effective paradigms for achieving environmental compliance. The following
discussion advances such a strategy.

tection, the following discussion describes

a strategy for effectively integrating NEPA
with an EMS. This strategy is designed specifically with adaptabilityin mind, such that
it can be adopted by any agency and applied
at virtually any level of federal program or
project implementation.

THE DILEMMA

WHY NEPA AND IS0 14000 EMS

COMPLEMENT ONE ANOTHER
As stated earlier, strong parallels exist
between the goals and requirements of
NEPA and those of the IS0 14000 EMS.
Although the following strategy is directed
at integrating NEPA with an IS0 14000 certified EMS, it could be applied equally to
integration with any EMS, that is consistent with the IS0 14000 standards. Hence,
as used in this article, the term EMS is interpreted to mean an IS0 14000 consistent

In 1969, the U.S. Congress established

the first policy enacted by a nation for protecting and safeguarding the environment.
While the National Environmental Policy
Act (NEPA) of 19691establishesa national
policy for protecting the environment, and
requires agencies to comply with certain
action-forcing mechanisms such as preparation of Environmental Impact Statements, the Act generally lacks a substantive mandate that requires agencies to
make decisions or take actions to protect
the environment.
Properly implemented, NEPA provides
a proven and powerful tool for formulating
policy and planning future federal actions.
Yet, NEPAs effectivenessas a planning tool
often is diminished because it either has
not been properly applied or integrated
into agency planning. As witnessed in this
article, strong parallels exist between the
goals and requirements of NEPA and the
specifications for implementing an International Organization Standards 14000
(IS0 14000) Environmental Management
System (EMS). Combining NEPA with an
EMS holds the promise for infusing NEPAs
substantive national policy goals into federal decisionmaking. As the third millennium approaches, such a strategy could
lead to more effective planning and enhanced environmental protection, while
streamlining compliance.
Devising an effective integrated process
that can satisfy the rigors of an international
standard and/or certification, yet does not
impact operational efficiency, requires a
combination of prudence and resourcefulness. To promote efficiency, minimize redundancy, and enhance environmental pro-

10 / Spring 1998 / ENVIRONMENTALQUALITY MANAGEMENT

EMS.
As outlined in the following paragraphs, not only are the goals and requirements of NEPA and IS0 14000 internally
consistent, their strengths and weaknesses
tend to complement one another. Exhibit
1 summarizes the similarities and synergistic strengths that an integrated NEPA/EMS
bring to one another. As indicated, a weakness in one system tends to be offset by the
strengths of the other. These similarities
and strengths are outlined in the following
sections.
The NEPA regulations identify categories of federal activities that are subject to
NEPA (Exhibit 2). It is important to note
that NEPA provides an inclusive framework for integrating and unifying early federal planning requirements and processes.
As depicted in Exhibit 2, establishment of
federal policies and plans is an action
subject to the requirements of NEPA. Accordingly, federal policies and plans established as part of an EMS potentially are
subject to the requirements of NEPA.

NEPA PROMOTES INTEGRATION OF

ENVIRONMENTALREQUIREMENTS
Under NEPAs implementing regula-

Charles H. Eccleston

Exhibit 1. Why NEPA and IS0 14000 Complement Each Other

Comparison

NEPA

IS0 14000

Goal

NEPA's goal is to protect the environment by ensuring that environmental

factors are considered during the early
planning process.

ISD's goal is to protect the environment by

identifying impacts and, using a system of
continual improvement, to reduce these impacts.

Mandate

Lacks a substantive mandate to protec'

the environment

Requires that substantive actions be taken, which

lead to continual improvement in environmental
protection.

Planning Function

Mandates that a comprehensive

environmental planning process be
conducted, but lacks an environmental
quality system for ensuring the
decisions are properly implemented.

Requires a planning function and provides a

system for ensuring that decisions are appropriately implemented, but does not prescribe a
detailed process for performing the planning
function.

External Input

Defines a detailed formal public

'scoping process" for identifying
significant impact and eliminating
nonsignificant issues.

Requires a procedure (not public) be used to

record and respond to external parties but does
not prescribe a detailed process for doing so.

Other Environmental
Requirements

Executive orders and CEQ guidance

direct federal agencies to integrate
pollution prevention measures,
environmental justice, biodiversity, and
a host of other considerations with
NEPA.

Requires a top-level environmental policy,

including a commitment to prevention of pollution
which is very broadly defined.

Life Cycle

Requires analysis of 'reasonably

foreseeable" impacts over the life
cycle of the action.

The IS0 14040 series describes in detail h o w t o

perform a life-cycle analysis.

Impact Assessment
Requirements

Provides detailed specifications for

analyzing direct, indirect, and
cumulative impacts.

Requires an investigation of "environmental

aspects." Little specificity is provided on the
requirements of this investigation.

Accumulated Environmenta
Experience

Nearly 30 years of experience has beel

accumulated in the planning and
analysis of significant environmental
impacts.

A relatively new requirement that has accumulated only limited experience in the planning and
anlaysis of significant environmental issues.

Significance

Defines specific factors for determinin!

the significance of environmental
impacts.

Provides no detailed direction for interpreting or

determining the meaning of 'significance."

Mitigation

Requires that mitigation measures are

identified and analyzed as part of the
planning processes.

Provides a system for ensuring that mitigation

measures are implemented.

Monitoring

Encourages (and sometimes requires]

post-monitoring measures.

Mandates monitoring as part of the continual

improvement cycle.

Continual Improvement

CEQ is promoting a cyclical process

based on "adaptive management."

A continual improvement process is a basic

concept inherent in an EMS.

tions, federal agencies are instructed to

integrate NEPA with other environmental
reviews (e.g., regulatory requirements, permits, agreements, project planning, and
policies) so that procedures run concurrently rather than consecutively; this requirement reduces duplication of effort,

A Strategy for IntegratingNEPA with EMS and IS0 14000

delays in compliance, and minimizes the

overall cost of environmental protection.2

* Integrate the requirements of NEPA

with other planning and environmental review procedures . . . (40 CFR
1500.2[clf

ENVIRONMENTAL OUALlTY MANAGEMENT / Spring 1998 / 11

Exhibit 2. Categories of Federal Activities Subject to NEPA

Federal actions tend to fall within one of the following categories (40CFR 1508.18[b]):
(11 Adoption of official policy. . . formal documents establishing an agency's policies which will
result in or substantially alter agency programs.
(2) Adoption of formal plans, such as official documents prepared or approved by federal agencies
which guide or prescribe alternative uses of federal resources, upon which future agency
actions will be based.
(3) Adoption of programs, such as a group of concerted actions to implement a specific policy or
plan.. .
(4) Approval of specific projects.. .
" . . . projects and programs . . . new or revised agency rules, regulations, plans, policies, or procedures (1508.18[a])."

"Actions include new and continuing activities, including projects and programs entirely or partly
financed, assisted, conducted, regulated, or approved by federal agencies; new or revised agency
rules, regulations, plans, policies, or procedures; and legislative proposals (1508.18[a]) . . ."

Identify other environmental review

and consultation requirements , . . prepare other required analyses and studies concurrently with, and integrated
with, the environmental impact statement. . . (40 CFR 1501.7[a1[61)
Any environmental document in compliance with NEPA may be combined
with any other agency document . . .
(40 CFR s1506.4)
The NEPA process already incorporates
extensive analytical and documentation requirements. With few modifications, a
"
A
analysis can be used to achieve conformance with IS0 14000 requirements.

Unforfunately,IS0
14000provides only
limited
specifications for
conducting the
planning function.

Planning Versus Implementation

Environmental planning is a mandatory element under IS0 14000. Unfortunately, IS0 14000 provides only limited
specifications for conducting the planning
function. Under IS0 14000, specific procedures and requirements for performing
scoping, investigating "environmental aspects," defining temporal and spacial
bounds, interpreting significance, and
other requirements are only, at present,
vaguely defined or inferred.
In contrast, NEPA's regulations provide
highly prescriptive direction and requirements for ensuring that an accurate and scientifically defensible analysis has been pre-

12 / Spring 7998 / ENVIRONMENTAL QUALITY MANAGEMENT

pared that provides decisionmakers with

information sufficient to reach an informed
decision. These requirements are reinforced
by nearly 30 years of experience, gained by
agencies that are engaged in diverse missions and environmental issues. Properly
combined, a NEPAEMS system provides a
synergisticprocess for planning actions and
implementing decisions in a manner that
protects and enhances environmental quality, while minimizing cost.

SUBSTANTIVE VERSUS PROCEDURAL

As viewed by the courts, NEPA is
largely a procedural requirement. An
agency must comply with the procedural
aspects of NEPA, but is not obligated to
select an environmentally beneficial alternative, or to demonstrate that its decision
conforms to the environmental goals established in Section 101 of the Act.
NEPA's contribution derives notkom a
substantive mandate to choose an environmentally beneficial alternative, but instead
from its procedural requirement forcing
decisionmakers to rigorously evaluate and
consider the effects of potential actions on
the environment, just as they would balance
other more traditional factors such as cost
and schedules. In contrast, an IS0 14000
consistent EMS involves a commitment to
take substantive actions to improve environmental quality. Not only must environmen-

Charles H. Eccleston

tally beneficial actions be taken, they must

be undertaken in a cyclical process of continual environmental improvement. Thus,
an EMS provides a mechanism for enforcing
the substantiveenvironmental mandate that
NEPA lacks.
Similarly, NEPA requires analysis of
mitigation measures but places no substantive mandate on decisionmakers to enact
such measures. In contrast, IS0 14000 requires organizationsto establish target objectives for improving environmental performance. Obtaining such targets necessitates
implementing actions similar to those of
NEFAs mitigation measures. Again, NEPA
prescribes more rigorous requirements for
planning and investigating mitigation measures, while IS0 14000provides the teeth
for implementing such measures.

ANALYTICAL SIMILARITIES
The NEPA regulations provide
highly prescriptive requirements to ensure that an accurate and defensible
analysis is performed, and thus to provide a decisionmaker with information
that supports informed decisionmaking.
NEPA is more demanding in requiring a
comprehensive analysis of direct, indirect, and cumulative impacts. In contrast, IS0 14000 requires investigation of
s ig n i f i c ant environment a1 asp e c t s ,
which are the specific activities that affect the environment. While the environmental aspects must be determined,
their environmental consequences or
impacts on environmental resources are
not required to be evaluated.
The NEPA process is reinforced by
nearly three decades of federal experience,
accumulated by a diverse range of federal
agencies, each faced with a unique organic
mission and a wide spectrum of environmental issues. From a planning perspective, NEPA provides a rich and more rigorous platform to ensure that environmental
impacts are identified, evaluated, and considered before a decision is made to pursue an action.

A Strategy for Integrating NEPA with EMS and IS0 14000

Life-Cycle Analysis
To the extent practical, NEPA requires
that an analysis be performed over the entire life cycle of an action, including connected actions. Both short- and long-term
effects must be considered. To the extent
possible, the reasonably foreseeable impacts of future actions must be identified
and evaluated. The IS0 14040 series describes in detail how a life-cycle analysis
should be performed. Integrating such requirements would reduce cost and paperwork.
Significance
Significance of environmental impacts
is a central theme to both NEPA and IS0
14000.NEPA requires analysis of potentially significant impacts of federal actions. The concept of significance permeates NEPAs regulatory provisions, which
include a definition and specific factors to
be used by decisionmakers in reaching determinations regarding significance. Not so
with IS0 14000. Under IS0 14000,significance is defined vaguely and contains
no factors for use in reaching a determination. Again, NEPA brings nearly 30 years
of experience to bear on the problem of
determining significance. NEPAs regulations provide specific publicly reviewed
factors, reinforced by case law, for assisting decisionmakers in reaching such determinations.

Under IS0 14000,

significanceis
defined vaguely and
contains no factors for
use in reaching a
deterrnination.

Integrating Pollution Prevention

The Presidents Council on Environmental Quality (CEQ)has issued guidance
indicating that, where appropriate, pollution prevention measures are to be coordinated with and included in the scope of a
NEPA a n a l y ~ i sA. ~number of federal agencies have also issued similar directives.
ISO-14000speaks to the merits of pollution
prevention, but mainly from the standpoint of establishing a top-level policy
committed to pollution prevention. Under
an integrated process, NEPA provides an
ideal framework to evaluate and integrate

ENVIRONMENTALQUALITY MANAGEMENT / Spring 1998 / 13

a comprehensive pollution prevention

strategy/plan, while IS0 14000 provides a
top-down policy to ensure that pollution
prevention is actually incorporated at the
operational level.

Decisions regarding
significance and the
choice of
alternatives are
high/y dependent on
the concerns of
stakeholdem.

Public Participation
As mentioned earlier, public participation is essential to the NEPA process. Decisions regarding significance and the
choice of alternatives are highly dependent
on the concerns of stakeholders. In contrast, the IS0 14000 series has no requirement for public participation, only a requirement to develop a plan for external
communications and inquiries. The lack of
such a requirement is a clear weakness in
almost all parts of IS0 14000. This is another case in which NEPA's three decades
of experience with public scoping and participation balance the weaknesses of an
IS0 14000 EMS.
Monitoring and Continuous Improvement
The NEPA regulations strongly encourage, and in some instances mandate, incorporation of monitoring. The courts, however, generally have not insisted that
agencies incorporate monitoring as part of
the NEPA process. In contrast, monitoring
is a basic element inherent in an EMS. A
properly integrated NEPA/EMS ensures
that monitoring is executed correctly.
Adaptive Management and Strategic Planning

Recently, CEQ has begun advocating

two new paradigms? The first, referred to
as adaptive management, consists of five
steps: predict, mitigate, implement, monitor, and adapt. The intent of this new approach is to allow mid-course corrections
based on the findings of environmental
monitoring.
Under an EMS, a monitoring step is a
basic element used to ensure that the
organization's environmental policy/plan
has been implemented properly. As appropriate, a plan is developed to correct deficiencies and improve environmental per-

14 / Spring 1998 / ENVIRONMENTALDUALITY MANAGEMENT

formance. The cycle is repeated. The EMS

plan/policy is revised and re-implemented. What appears to have gone largely
unnoticed is that adaptive management is
not only consistent with, but is in fact surprisingly similar to, the continual improvement cycle underlying an EMS (see
Exhibits 3 and 4).
The second paradigm, referred to as
strategic planning, incorporates a collaborative approach for identifying and solving
environmental problems within the
agency's internal planning process, at the
early planning stages. An EMS could provide a crucial mechanism for integrating
strategic planning into agency operations.

STRATEGY FOR INTEGRATING AN EMS .

WITH NEPA
A strategy for integrating an EMS with
NEPA is depicted in Exhibit 3. Conceptually, Exhibit 3 is composed of three discrete functions or phases: (1)centralized
planning and decisionmaking, (2) implementation, and (3) environmental monitoring and enforcement.
Policy Planning Phase
The proposed scheme is initiated with
the step of establishing a high-level organizational environmental policy and a commitment to environmental quality (see first
block, Exhibit 3). Next, an effort is mounted
to develop a specific plan for implementing
the environmental policy (see second block,
Exhibit 3). Drawing on expertise and experience from a diverse array of planning requirements and entities, an interdisciplinary
effort is used in developingan Environmental Implementation Plan (EIP). The EIP
might be prepared for a major federal prog r a m or installation; in other cases, an EIP
might be prepared for a particular facility,
operation, or a project-specific action. Here,
NEPA provides the interdisciplinary framework for integrating and coordinating all
early environmental planning, reviews, and
analyses necessary to support formulation of
the EIP. Thus, the EIP might incorporate an

Charles H. Eccleston

array of related environmental issues such

as pollution prevention, safety procedures,
habitat management practices, environmental justice, sustainable development, and
other related goals or disciplines.

Analysis, Significance, and

Decisionmaking
In the third block of Exhibit 3, NEPA
documentation is prepared for projects/
plans having a potential to directly, indirectly, or cumulatively affect the quality
of the human environment. NEPAs public scoping process is used to obtain public input and sort significant issues from
nonsignificant issues. Consistent with
NEPA, scenarios and alternative approaches are investigated as part of the
process for developing the EIP. Actions,
alternatives, and impacts are evaluated
pursuant to the requirements of NEPA,
and any additional requirements that
might be promulgated as part of the EMS.
This analysis also can be used to prepare
an emergency response plan, thus satisfy-

ing an important EMS requirement. As described earlier, NEPAs definition of significance and its ten significance factors
could be used to reach final decisions
about the EIP and actions pursuant to
implementing the EMS [see fourth block,
Exhibit 3).

Implementation Phase
Once the EIP is completed and a final
decision is reached, an effort is begun to
implement the EIP/final decision. A centralized planning function could be used to
coordinate implementation of the plan
within the respective federal facilities and
operations. At the lower facility or operational level, Environmental Compliance
Officers (ECOs)or equivalents could be assigned responsibility for preparing a more
detailed site-specific Facility Implementation Plan (FIP) for implementing the EIP,
thus satisfying the fifth block shown in Exhibit 3.
Under this scheme, the EIP provides
high-level direction and constraints that

Exhibit 3. Conceptual Process for Integrating an EMS with NEPA

A Strategy for Integrating NEPA with EMS and IS0 14000

ENVIRONMENTAL QUALITY MANAGEMENT / Spring 1998 / 15

the FIP must meet. Thus, individual FIPs

could be tiered from the EIP, providing
facility/project-specificdirection for implementing results of the planning process by
way of the EMS. The centralized planning
office could be assigned responsibility for
approving each FIP so as to ensure continuity and consistency. Implementation problems and cross-cutting issues also could
be elevated to the centralized planning office for resolution.
Furthermore, the EMS requires extensive job-appropriate training of all affected
employees, to ensure that the FIPs are
implemented correctly. Defining and tracking the appropriate training requirements
could be a centralized function, while performing training is an operations-specific
function.

Monitoring and Enforcement Phase

As depicted in the sixth block of Exhibit 3, a centralized oversight office could
be assigned responsibility for performing
reviews and monitoring facility and opera-

tional compliance. An ECO (or equivalent)

could be assigned responsibility for preparing and transmitting input and status reports to the oversight office. Audits could
be performed periodically by the oversight
office to verify compliance.
The monitoring data are evaluated to
verify compliance and effectiveness of the
EMS in meeting the established policy and
plan. As appropriate, the organizational
policy/plan is revised to correct deficiencies (see loop branching to box labeled
Corrective Action, Exhibit 3). Substantial changes could be made at the centralized planning level, while less significant
changes might be implemented at the facility level by revising the FIP. The ultimate
concept behind an EMS is that impacts
will eventually dissipate, such that the
next plan might address impacts different
from those in the existing plan. Such a process ensures a continuous improvement
cycle, which is the hallmark of an EMS,
and also promotes CEQs paradigm of
adaptive management.

Exhibit 4. Simplified Overview of a Typical Environmental Management System

16 / Spring 1998 / ENVIRONMENTALQUALITY MANAGEMENT

Charles H. Eccleston

NOTES
1. T h e N a t i o n a l Environmental Policy Act of 1969, as
a m e n d e d ( P u b l i c Law 91-190.42 U S C . 994321-4347,
January 1, 1970.

2. CEQ, Regulations for Implementing the Procedural

Provisions of the National Environmental Policy
Act, 40 CFR, P t S . 1500-1508, 1978.
3. CEQ, Guidance on Pollution Prevention and the
National EnvironmentalPolicy Act, published a t 58
FR 6478, J a n u a r y 29, 1993.
4. CEQ, The National Environmental Policy Act: A
Study of its Effectiveness After Twenty-Five Years,
1997.

Charles H. Eccleston is a principal scientist with the

NEPA Group, Waste Management Federal Services of
Hanford Inc. He is chairman of the Tools and Techniques (TNT) NEPA Practice Committee which is chartered under National Association of Environmental
Professionals with responsibility for establishing nationally Accepted Methods of Professional Practice
(AMPPs)for streamlining andimproving the effectiveness of the NEPA process. Recently, he participated
as a member of a White House sponsored task force

A Strategy for Integrating NEPA with EMS and IS0 14000

established to provide recommendations and support

for the Council on Environmental Qualifys Reinventing NEPA Initiative. This article is an outgrowth of this
effort.
The author would like to acknowledge Dr. J.A.
Roberts (President, National Association of Environmental Professionals) and Mr. A.J. McCusker (President-Elect National Association of EnvironmentalProfessionals) who reviewed this article with respect to
its programmatic implications; Ms. R.C. Schenck (U.S.
TechnicalAdvisory Group, IS0 14000 Standards), who
reviewed and provided comments on the article from
the perspective of IS0 14000. Special thanks are extended to Ms. S.A. Resetar (EnvironmentalPolicyAnalysts, RAND Corporation) who provided insighlful comments, particularly from the perspective of this
approach in terms ofnational environmentalpolicy and
clarity of the overall concept. Mr. F: March (NEPA
Working Group-Chairman, National Association of
Environmental Professionals) and J.L Lee (President,
Environmental Planning Strategies, Inc.) contributed
valuable suggestions with emphasis on NEPA. Finally,
Mr. TL Kuusinen (Pacific Northwest National Laboratories)reviewed the article from a comprehensive environmental standpoint.

ENVIRONMENTALQUALITYMANAGEMENT / Spring 1998 / 17