A Green Bible

PLOTTING A GREEN ‘BIBLE’

Good environmental management is not achieved by strategy embodied in a document that sits on a shelf. There is much more to it as Felicity Landon explains

Most ports have an environmental policy in place of one sort or another – but is it fi t for purpose, how should it work, what should ports be prepared for, and how do smaller ports with fewer resources take on a challenge that larger ports can throw their own specialists at?

Nigel Coulshed, Environmental Associate with Independent Port Consultants (IPC), often avoids the ‘E word’ altogether when advising on construction projects – as he points out, there are numerous reasons based on self-interest for doing the right thing, from improving customer confidence to business efficiency.

“People can be dismissive of the word ‘environment’, but often there is a business case for doing these things properly. However, the thing with an EMS (Environmental Management System/Plan) is to make sure the tail doesn’t wag the dog – it should be appropriate for the place, and not so prescriptive that it is unworkable.”

For example, drainage needs to be managed carefully to prevent any run-off polluting a watercourse with fish in. “The question is, wouldn’t it be better to have a dry site, so you don’t get run-off or vehicles getting bogged down, and you get a tidier site with less slips and trips?”

When ports and others were adopting ISO 14001 in its early days, they tended to go overboard, he says, “but now people are more sensible and ensure the documents are fit for use”.

His advice includes – you can’t change what you don’t measure, you can’t measure without a baseline, and ignorance is no defence. In difficult cases, how can you defend yourself against accusations of pollution if you don’t know the baseline position – for example, that there is historic contamination of a site that has nothing to do with you, or that your neighbour is or was causing pollution?

IGNORANCE NOT A DEFENCE

Ports can focus so much on “micromanaging” the impact of their own activities that they may be completely unaware of what’s happening beyond the border, says Coulshed. “For example, they may think that a Special Protection Area next to the port is not really an issue for them. There may be special birds breeding, for example. Most ports are familiar with these things now, but ignorance isn’t defence.”

Legislation is obviously a driver for ensuring a robust environmental policy – but it is not the only one. Where there is best practice guidance in place “it is frowned upon if you don’t adhere to it”, he says. “For example, it is recommended you don’t refuel within a certain distance of a water body – and it becomes your fault if you do, and something goes wrong.

“If you don’t have any environmental incidents, you don’t have any related stoppages and you can continue to make money, avoiding the likely costs of any stoppage for health and safety or environmental reasons. The two are often linked – if you have good control and understand what your likely risks are regarding pollution and air quality, etc., you can be more efficient in the way you manage your operation. It might slow you down a bit, but it makes you more efficient over the years. It also makes you more attractive, customers gain confidence in you, and there is a knock-on effect for insurance.”

He believes that environmental monitoring is more important today than it has ever been. “First, you need a baseline of what is already there – maybe it was already a polluted environment. If you have an incident, you can measure exactly what was your fault and what was not your responsibility. Monitoring is also important if there is an issue with dust and for the effectiveness of control mechanisms and mitigation – unless you monitor what you had before and now, you can’t measure performance

8 Air quality is

identifi ed as the one concern for ports striving to put in place eff ective environmental management measures

or differences. The same goes for noise – people assume noise comes from the port, but it might not necessarily be so.”

Finally, having the policies and response processes in place is all very well – but if no one has a grasp of them, what use are they?

“The core thing in being able to respond, make sure health and safety is in place and people aren’t going to be injured, and protect the environment, is that people are given control and training,” says Coulshed. As he says, at a time of crisis, you should not be asking ‘how do I respond’ and start reading through a massive document.

“People must be trained properly – an EMP doesn’t work if you have to go to a document and look up what you are supposed to do.”

SMALL PORTS: OUTSIDE HELP

While large ports usually have their own environmental teams and resources to put together their policies and strategies, smaller ports will likely need outside help – and consultants can also advise on issues that a port may not have considered. However, that does not mean handing the whole headache to someone else and forgetting about it.

“The whole point of having an EMP is that you need to be able to implement it. You can get a consultant to write it, but you could end up unable to function or with procedures you can’t follow. The port must be the author, under the guidance of the consultant.”

Too many ports use language such as ‘we will consider’ or ‘we will endeavour to’ – and that isn’t good enough, he adds. “You need to set targets and objectives for managing environmental concerns.”

He recalls working with one port that had “amazing documentation” and environmental accreditations as part of a due diligence assessment, “but when I spoke to the people within the port organisation, they didn’t have a clue about the questions I was asking. A consultant had written the whole thing for them, and they didn’t have a clue about what they said they had done.”

ESPO 2020 ENVIRONMENTAL REPORT

The European Sea Ports Organisation (ESPO) 2020 Environmental Report provides insights into environmental management from research in the EcoPorts network. Based on a sample of nearly 100 small and large ports all over Europe, it shows that ports are increasingly engaged in environmental management, says Valter Selén, Senior Policy Adviser for Sustainable Development and EcoPorts Coordinator at ESPO.

The report notes a number of positive trends – including that 81% of surveyed ports have an environmental monitoring programme in place. “Linked to this is the existence of an Environmental Policy, with 96% of sample ports having such a policy,” says Selén. “In this document, the port authority clearly states its intentions and principles in relation to its overall environmental performance.”

The existence of an inventory of Significant Environmental Aspects (SEA) is another important indicator, he says, with 92% of surveyed ports having such an inventory – a level which has been sustained over time. “The inventory is a critically important component of any credible EMS, as it represents the elements of the port activities, products and services that may impact on the environment.”

The report also demonstrates that ports have improved their performance in areas such as publication of publicly available environmental reports, and training programmes for employees. Some 91% of ports communicate their environmental policy to stakeholders, with 86% making it available on their website.

Air quality is the top environmental priority for ports, followed by climate change – which has risen from tenth priority in 2017 to second priority in 2020, with energy efficiency the third priority.

More than half of the responding ports offer on shore power supply (OPS), and one third of them have made LNG bunkering available. An increasing number of ports (57%) provide differentiated dues for ships that go beyond regulatory standards, with air emissions, waste and climate change being the main targets of these discounts.

In addition to its existing ‘Good Green Practices Database’ database available online, ESPO is preparing to publish a Green Guide, “which seeks to address the need for additional guidance in this area by providing hands-on advice for ports and policymakers engaged in greening”, says Selén.

8 ESPO is preparing

to publish a Green Guide, “which seeks to address the need for additional guidance by providing hands-on advice for ports

An EMP doesn’t work if you have to go to a document and look up what ‘‘ you are supposed to do

BRITISH PORTS ASSOCIATION: NETWORKING

While the British Ports Association does not provide formal advice on environmental management plans, its members don’t hesitate to phone and talk to each other about their experiences and initiatives, says Mark Simmonds, BPA Director of Policy & External Affairs.

“Ports do tend to talk to each other. Through our networks a lot of them share good practice about what other ports are doing.” He says size isn’t necessarily a factor in good environmental management and it’s easy to find smaller ports with a good record. “It’s a mix – the size of the port hasn’t really much correlation with how good they are (or are not) at environmental management.”.

The BPA is preparing to launch a decarbonisation programme, which will include provision for more formal sharing of good practice, says Simmonds. “As an association, we are getting better at sharing good practice – for example, with case studies – and we are trying to formalise some of that in an effort to show everyone what others are doing.

“People don’t always realise this work is going on. A lot of ports don’t blow their own trumpet.”

Why don’t they tell people what’s happening? “They see it as part of their job and don’t realise that people will be interested or grateful for it.”