Connecting the Environmental Management System and Environmental Impact Assessment for Pipeline Projects

The National Energy Board of Canada (NEB) oversees all aspects, including environmental protection, of the construction and operation of hydrocarbon transmission pipelines under federal jurisdiction. The NEB’s regulatory approach is to minimize regulatory burden while maintaining a high standard of environmental protection. To achieve this, the NEB is working toward implementing a flexible, risk-based regulatory approach in which processes fit the scope and range of applications it receives. The NEB requires its regulated companies to develop and implement the equivalent of an environmental management system relating to all aspects of their business. In evaluating the companies’ compliance, the NEB conducts formal audits of these systems to ensure they are appropriately developed, maintained and implemented. The NEB has recently initiated changes to its regulatory processes to utilize companies’ management system information collected during the audits to enhance its application and assessment processes. This paper will discuss how concepts related to risk and management systems principles and information collected during an environmental management system audit can be integrated into a regulator’s environmental impact assessment for a proposed pipeline project. How knowledge and lessons learned are transferred through all stages of the pipeline life cycle will also be discussed.