§ 15 Environmental Management: the model of the environmentally equipped industrial area (Riccardo Beltramo/Stefano Duglio/Maria Beatrice Pairotti) Abstract
Il lavoro intende analizzare alcuni esempi di sforzi verso uno sviluppo industriale più sostenibile, partendo dalla teoria dell’ecologia industriale, diffusa a livello internazionale nelle forme di parchi Eco-industriali e focalizzando poi l’attenzione su una forma particolare di area industriale, nata in Italia attraverso una legge del 1998 e denominata Area Produttiva Ecologicamente Attrezzata (APEA) nella quale coesistono più imprese che dialogano fra loro e all’interno della quale si potrebbero adottare alcuni assunti tipici dell’ecologia industriale. Il lavoro si concentra sula modalità di gestione di questo modello di area con particolare riferimento al controllo degli aspetti ambientali in relazione alla normative cogente. In particolare, la necessità di definire un sistema di gestione d’area, uno dei requisiti fondamentali introdotti per legge, trova risposta nello strumento del Sistemi di Gestione Ambientale, come introdotto dal Regolamento Europeo EMAS.0 Esso, oltre a supportare l’impresa nella gestione ambientale dei propri processi, prevede la redazione di una Dichiarazione Ambientale, attraverso la quale il cittadino ha la possibilità di conoscere il profilo ambientale dell’organizzazione, la legislazione applicabile e gli obiettivi di miglioramento.
Inoltre, considerando che un’Area Produttiva Ecologicamente Attrezzata insiste su di una porzione di territorio, sulla base di alcune esperienze locali si discute sull’estensione del sistema ambientale verso la valutazione dell’incidenza sul paesaggio, attraverso l’implementazione di un Sistema di Gestione Ambiental-Paesaggistico (SGAP), che, integrando quanto espresso dalla Convenzione Europea sul Paesaggio, consenta una partecipazione attiva del cittadino ai processi decisionali.
I. Introduction
Enhancing efforts towards more sustainable development is now a common universal goal. The latest data published by the Intergovernmental Panel on Climate Change (IPPC), an international body founded by the United Nations Environmental Program (UNEP) and the World Meteorological Organization (WMO), highlights the critical situation we will have to face in the coming years. According to the Panel; “global mean temperatures will continue to rise over the 21st century if greenhouse gas (GHG) emissions continue unabated […]” and in the field of climate change there could be an increase in long term temperature levels in the range of 1˚C to more than 5˚C with consequences that are difficult to foresee.0
0 European Regulation n. 1221, European Union Official Journal of 25th November 2009.
This is not a recent issue, however. Since the mid-1970s, the political, economic and academic worlds have increasingly been interacting in order to define programs, objectives and actions useful to achieve the goal of a more eco-efficient development in an inclusive society. Starting from 1987, with the publication of the well-known Brundtland Report containing the definition of sustainable development0, the last 30 years have produced several documents, resolutions, protocols and charters, which have been published in order to increase the commitment of the political world as well as the awareness of the public.
In this general context, great attention has been paid to the industrial sector, allowing the launch and development of the Industrial Ecology Theory in the late 1980s, that introduced ideas to reduce the impact of industrial activities on the environment, beginning with analyzing the natural system. It is widely known that due to the definition of Eco Industrial Parks (EIP), that industrial areas which actively monitor the reduction of their environmental impacts permit a more sustainable industrial production. One of the first of these areas, located in Kalundborg in Denmark, has become a sort of model on which other EIPs have been developed, starting from government initiatives or on the part of the industrial areas themselves.
In Italy, the most recent discussion in this field has included the creation of a new framework: the Ecologically Equipped Industrial Area (EEIA), introduced by a specific national regulation; the no. 112 issued in 1998.0
This paper focuses on the concept of the EEIA and its characteristics. Specific attention is paid to the relationship between the EEIA, its general management and applicable legal requirements, by means of specific environmental tools, useful to communicate the environmental data to stakeholders on the one hand, and to facilitate public participation on the other hand.
II. Industrial Ecology and Eco Industrial Park (EIP)
The Eco Industrial Parks (EIPs) can be defined as a “community of manufacturing and services companies seeking enhanced environmental and economic performance through collaboration in managing environmental and resource issues including energy, water and materials […]. Trough collaboration, this community can become an industrial ecosystem”0. The EIPs are, in fact, one of the main applications of industrial ecology, a part of sustainability sciences and can be explained as a multidisciplinary framework that links the industrial system with the natural one with the aim of minimizing the industrial impact on the environment. It is based on the idea that industrial areas should be designed to resemble natural ecosystems in order to use energy, water and material resources in an optimal way, minimizing waste.0 Ayres developed the comparison between the natural and the industrial systems, using the concept of industrial metabolism, that represents “the whole integrated
0 According to the Brundtland Report, sustainable development can be defined as the “[…] development that meets the needs of the present without compromising the ability of future generation to meet their own needs” WCED (1987), 43.
0 Official Journal n. 92, 21th April 1998
0 Definition available in Sendra et al. (2007), 1706
collection of physical processes that convert raw materials and energy, plus labor, into finished products and wastes in a, more or less, steady-state condition”0.
Following the ideas of Ayres, it is necessary to develop different approaches to the existing problems of pollution: for instance, as far as waste is concerned, disposal does not represent the right solution, considering that it is not an ultimate solution. An improved option can be identified in the closing cycle of production, which reproduces the operating model of a natural system. Waste resulting from a production cycle, could become raw material for another after a process of recycling (if necessary). The reduction of raw materials and energy consumption is one of the first results of this theory: a general reduction of the environmental impact could be obtained in the area where these actions are applied and also a minimization of waste management. The whole system could obtain positive effects, for instance: in the reduction of transport and their consequential pollution and may also strengthen links of cooperation among companies.
Frosch and Gallopoulos introduced the concept of an industrial ecosystem in analogy with the natural system.0 When analyzing a natural system, it is possible to observe that all the materials used represent raw materials for other organisms in a sort of closed cycle: they do not however represent waste but are used as materials and energy necessary for other processes. Following the principles of industrial ecology, an industrial system could reproduce this operation and reduce the needs of materials and energy and the consequent production of waste. To create such a performing system is a difficult exercise: yet, using the theory of industrial ecology, it could be possible to adopt some principles to plan industrial areas, which could better integrate themselves into the environment, where materials and energy are exploited in a comprehensive way, thereby reducing dependency from outside processes and producing less waste.
The results of the studies carried out on the area of Kalundborg have been exported into other European countries and also outside Europe. Some examples of other areas include; the Styria Region (Austria, EU), Value Park (Germany, EU), Londonderry (New Hampshire, USA), Burnside Park (Nova Scotia, Canada), Kwinana Industrial Park (Australia), and Ulsan (Korea).0
III. Management of industrial areas in Italy
In Italy, the effort towards a more sustainable industrial development stems from law. The model chosen to develop a new kind of sustainable industrial area: the Ecologically Equipped Industrial Are (EEIA) entails the following of specific rules as to environmental management and planning. These rules have been introduced by national law and are regulated at local level. The areas could be new ones, or even more beneficially; the renewal of brown fields. The legislative decree that introduced the concept of the EEIA is no 112 of 19980 establishing that: each region can regulate the management of the EEIA separately. This law specifies the
0 Quoted in Ayres (1997), 3
0 Presented in Frosch, Gallopoulos (1989), 144-145
0 Quoted in Mathews J. and Tan H. (2011), 446 and Beltramo (2009), 20-66. 0 Official Journal n. 92, 21th April 1998.
possibility of reducing the quantity of compliance for companies and the following common features for all areas:
1. presence of a general manager in the area; 2. Common and shared facilities;
3. Realization of a common environmental management system; 4. Involvement of local public bodies in making decisions about areas.0
These four pillars are the core ideas of EEIAs. The general manager represents the interests of all the bodies involved in an industrial area. They have different tasks, starting from facilities and environmental aspects management (its role is fundamental in the establishment of a common environmental management system); the general manager could include: private or public components or companies’ exponents, to represent the interests of local bodies involved. The aim is to safeguard all the interests and to assure the best management of the area.
The participation of governments of the towns involved is also envisaged. The participation of citizens, by means of their representatives in the decisions regarding the industrial areas, leads to a better integration of the area itself in the territory. The realization of common facilities and services, like logistical means of operation for materials, people or waste disposal, contributes to reducing the impact of industrial activities, to creating synergies among companies, and to improving the environmental and social image of the industrial area.
Following these general principles, each region can intervene on this matter by means of its own rules: some regions have prepared their guidelines to allow industrial areas to change towards this new kind of area. The Marche Region was the first to introduce the guidelines for EEIAs in 2005 by Regional Law no. 16 and an update of this document has been adopted recently.0 In the previous version, the Region had introduced two documents, one as to good practices for environmental management of this kind of area and one as to pilot cases in the regional territory. The province of Bologna (located in the Emilia Romagna Region) published its guidelines about EEIAs in the Regional Committee Resolution no. 407/2006, which was updated in 2008.0 The Piedmont Region also intervened in the field of EEIAs by introducing guidelines published by the Regional Committee Resolution no. 30-11858 in 2009.0 Finally, the Tuscany Region also published guidelines in a Regional Committee Resolution 1245 in 2009 after other normative activities in the previous years.0 In 2013, Sardinia introduced its rules by the Regional Resolution no. 4/2.0
IV. Management of the EEIA
0 Quoted in Vesce et al. (2014), 1; Regione Emilia Romagna et al. (2010), 8-13, Cariani R. (2013), 41-78, Beltramo et al. (2010), 192 and Vesce et al. (2010), 15.
0 Available at www.ambiente.regione.marche.it/ambiente/areeproduttiveecologicamenteattrezzate.aspx 0 Available at
www.provincia.bologna.it/imprese/Engine/RAServeFile.php/f/APEA/Linee_guida_APEA_Ott2008.pdf and quoted in Bollini G., Borsari L., Stacchini V. (2007), 75-76
0 Available at
http://www.regione.piemonte.it/territorio/dwd/documentazione/pianificazione/LineeGuidaAPEA.pdf 0 Quoted in Regione Toscana (2012) and in Gallo P., Gianfrate V. (2011), 1006-1014
1. Environmental Management System (EMS): a tool for the management of the EEIA
One of the strong points in applying the EEIAs is represented by the necessity to realize a specific system able to manage the environmental aspects of the area. Although the guidelines of the different Italian regions contain some differences and do not completely explain how the systems should be built, in all cases however, they all start by drafting an environmental preliminary analysis in order to define the environmental objectives contained in the programme.
These two documents, and more specifically the environmental preliminary analysis, also represent the basis of the Environmental Management Systems (EMS), implemented in accordance with international standards i.e. ISO 14001: 2004 Standard or the European Regulation Eco-Management and Audit Scheme (EMAS)0. In confirmation of this last assertion, some of the guidelines quoted for instance, explicitly refer to these tools for the creation of the system and have indicated that both tools provide a good knowledge of the area and a useful planning of all the environmental actions to be undertaken in the future. Considering that more than one company is involved, Tuscany underlines that it is necessary to refer to specific documents regarding EMAS, as the guidelines introduced in Tuscany by the Life Project Pioneer “Paper Industry Operating in Network: an Experiment for EMAS Revision”0 and the document referring to EMAS for production areas with similar features.0 Piedmont introduced a range of levels to obtain the title of EEIA: the starting point is the adoption of an EMS, the references used are both the ISO14001 Standard or the EMAS Regulation. The next steps are the implementation of other systems; concerning safety, land attention, and social responsibility. These systems must be connected and integrated with each other. Sardinian guidelines refer to EMAS for the definition of environmental preliminary analysis. In both tools i.e. ISO 14001: 2004 and EMAS, the EMSs are created in accordance with the Deming Cycle approach that divides the system into four phases: Plan, Do, Check and Act. 0
Without focusing on the details of the implementation of EMSs, a brief overview of the strong points of the system may help to understand the importance of the tool, especially when it is applied to the management of an EEIA and meets the environmental legal requirements. The starting point is represented by the Environmental Preliminary Analysis (EPA). Due to this instrument, the organisation takes into account the environmental implications of its processes and the applicable legal requirements.
Moreover, attention is paid to evaluating the relevance of the environmental aspects, and a procedure specifically aimed at identifying and checking the regional and national legislation should be created (Plan Phase). The Do Phase is dedicated to the implementation of all the
0 European Regulation n. 1221, European Union Official Journal of 25th November 2009.
0 LIFE03 ENV/IT/00042, available at http://ec.europa.eu/environment/life/project/Projects/index.cfm? fuseaction=search.dspPage&n_proj_id=2379&docType=pdf.
0 Comitato per l’Ecolabel e per l’Ecoaudit Posizione del Comitato per l’Ecolabel e per l’Ecoaudit
sull’applicazione del Regolamento EMAS sviluppato in ambiti produttivi omogenei approvata dalla Sezione EMAS del Comitato per l’Ecolabel e per l’Ecoaudit il 28/01/2005.
procedures necessary for implementing the system (communication, training, documents, etc.), while in the Check Phase, the organisation should verify the correct implementation of the system and once again, continuous respect of the law.0 Lastly, the Act Phase concentrates on the evaluation of the system and the identification of the future strategies and objectives. 0 As already mentioned, the “weight” of the environmental legislation in the implementation of an EMS is fundamental. The legal requirements are taken into account at three different levels in an EMS: the preliminary analysis, the Plan and the Check Phases, and compliance with all environmental legal requirements, which is the conditio sine qua non for being certified. For this reason, EMSs have been used by all the kind of organisations (enterprises as well as public bodies) since their first publication (1995 for EMAS and 1997 for ISO 14001: 2004), as several authors show in their studies focused on the motivations and benefits from the adoption of EMSs. 0
The application of EMS into the context of EEIAs, should be a strategic phase in the development of the same EEIAs as it allows it to:
1) systemize environmental aspects among productive firms that produce various goods or provide services;
2) facilitate exchange among enterprises. Such an action should involve a decrease in the amount of waste production as well as the consumption of electricity and/or non-renewable energy sources (gas and oil); and
3) guarantee the respect of legal requirements by all the organisations involved in the EEIA, with a consequently positive repercussion in terms of safety for the citizen.
In addition, if the adoption of both the ISO 14001 and EMAS guarantee the aforementioned objectives, in the second case, the EEIA should also compile and communicate the Environmental Declaration. The Environmental Declaration, which is not provided by ISO 14001, communicates to stakeholders – in primis the citizens – all the necessary information related to the environmental system – processes, environmental implications, legal requirements, and objectives. This fosters the implementation of one of the “three pillars” of the AC i.e., the access to information by the public.
2. From the EMS to the Environmental and Landscape Management System (ELMS)
The main characteristic of EEIAs is that it is an industrial area in which different kinds of enterprises can cooperate in order to share facilities and to improve the industrial ecology issues. The presence of a relatively wide area, depending on the number and the size of the single enterprises involved, is a characteristic that should be taken into account when implementing the system.
0 European Regulation n. 1221, European Union Official Journal of 25th November 2009.
0 As reported in several studies: Gonzáles-Benito J. and Gonzáles-Benito O. (2005), 135; Perotto et al. (2008), 518; Beltramo et al. (2014), 20-21.
0 As shoved by Morrow D. and Rondinelli D. (2002), 165-166; Chang E. and Wong S. (2004), 489-490; Gavronsky I. et al. (2008), 91-92.