I talk about continual improvement as if industry will instigate it. However, government departments are constantly reviewing their systems and processes to determine what works and what doesn’t work well. Changes to ensure continual improvement often occur and have an impact on the content of approvals documentation and resulting activities during the construction and implementation of a project. As industry professionals, we need to keep abreast of topics raised by the research community.
Two papers have recently been published (Lee 2014; Lee and Gardner 2014), which specifically critique the reference to adaptive management, in approvals documentation, as a way of managing potential unknown impacts from water drawdown.
The intent of adaptive management is to provide flexibility when addressing unknown impacts or risk of environmental impact in instances where there is uncertainty. The process for implementing adaptive management regimes is illustrated in the figure below.
While in theory, the use of ‘adaptive management’ in approvals documentation is sound but in practice Jessica Lee (2014) states, “adaptive management is nothing more than a ‘political catch phrase’ or ‘comforting gesture’ that loosely promises some answer to future circumstances.”
I often hear environmental personnel complain that approvals specialists make promises that cannot be implemented or complied with, and this may well be an example of a vague term used by approvals specialists that doesn’t mean much to people in the field.
Jessica Lee considers two Western Australian mining projects that have used the term ‘adaptive management’ in their approvals documentation. Lee constantly highlights the use of indefinite terms subject to interpretation (e.g. significant, excessive), vaguely stated objectives and triggers, and lack of substantive groundwater standards among other things.
Lee (2014) made the following recommendations:
- Legally define the content of adaptive management.
- Integrate adaptive management planning into EIA documentation.
- Set substantive objectives and standards in law.
- Set binding and legally enforceable obligations to adapt with clear, quantitative and measurable triggers and specific adaptive responses.
While these recommendations were specific for groundwater management, don’t be surprised if further investigation and up-front detail and commitments are required by the EPA during the Environmental Impact Assessment process in instances where adaptive management processes are used to address uncertainty.
Lee, Jessica. 2014. Theory to practice: Adaptive management of the groundwater impacts of Australian mining projects. EPLJ 31: 251 – 287.
Lee, Jessica and Alex Gardner. 2014. Comment. Peek around Kevin’s Corner: Adapting away substantive limits? EPLJ 31: 247 – 250.