2. Drafting (PHASE I)

The following activities must be carried out for an EMSP (adapted from Michaud, 2000):

Formulation of the EMSP objectives.
Development of verifiable hypotheses of effects or impacts that will allow the EMSP to achieve its objectives.
Preparation of the physical, chemical and biological characterization plan:
- determine and describe the assessment and measuring parameters that seek to confirm or reject the hypotheses;
- determine the criteria these parameters must meet to be able to confirm the hypotheses (e.g., precision, accuracy, detection limits, reproducibility);
- define the means used to guarantee the quality of the data;
- define the data processing and interpretation criteria, both from the perspective of confirming hypotheses and achieving objectives;
- determine the statistical methods used to process the data.
Drafting of the contingency plan.
- in the event of confirming non-zero impact hypotheses, determine the responses that should be implemented to mitigate or eliminate these impacts;
- identify the persons responsible for implementation of the responses.

As a general rule, the basic information (project activities and components of the environment) necessary to draft an EMSP can be found in the reports and records regarding the environmental assessment of the project concerned.

2.1 Objectives of the EMSP (Activity 1)

The first activity in drafting the EMSP involves describing the problem associated with the project under study (section 2.1.1) and formulating the objectives of the EMSP (section 2.1.2). Formulating the objectives of the EMSP makes it possible to identify the monitoring and surveillance needs. In general, the environmental assessment of the project provides the majority of the information needed to carry out this first activity as a whole.

2.1.1 Description of the Problem

The description of the problem seeks to identify the activities likely to result in impacts on any environmental components. Integrating the information gathered to describe the problem makes it possible to define the scope of the EMSP.

The description of the problem includes the context, identification of the available resources and drafting of the applicable timelines.

The following elements must be considered:

the dredging and sediment management activities that must be covered by the EMSP: scope of the dredging project (duration, volume, technology used, etc.);
the environmental components likely to be affected and identified in advance during the environmental assessment of the project (see Box A-2 of Appendix A);
the applicable legislation and regulations, as well as the commitments made by the proponent and enshrined in the authorization records;
the organizations, individuals and stakeholders interested in the problem;
the timelines projected by the EMSP.

Most of the information required can be found in the project’s environmental assessment reports. Moreover, examination of the previous studies involving the site concerned or pertaining to similar problems is useful to identify elements relevant to the description of the problem.

2.1.2 Formulating the Objectives of the EMSP

In general, an EMSP should have one or more of the following objectives:

For surveillance:

ensure compliance with the legislation and regulations in force, and the conditions set out in the decrees, permits, certificates of authorization, specifications and dredging contracts;
verify the validity and effectiveness of the measures taken to mitigate or offset the negative impacts anticipated during the performance of the work;
verify the anticipated environmental effectiveness of the technologies and materials used;
assist the proponent in quickly taking the appropriate measures to mitigate or offset the impacts (via the contingency plan), if a mitigation or offsetting measure proves to be ineffective during the performance of the work or in the event of impacts unforeseen or underestimated in the environmental assessment.

For monitoring:

verify, over a specified period generally exceeding the period of performance of the work:

the accuracy of the project’s anticipated impacts on important elements of the ecosystem, particularly those that presented a high level of uncertainty;
the validity and effectiveness of the measures to mitigate or offset the anticipated negative impacts;

allow a rapid reaction if a mitigation or offsetting measure proves to be ineffective or in the event of unforeseen impacts after completion of the work;
improve the forecasting capacity of the subsequent environmental assessments;
observe the effects of implementation of new technologies;
eliminate the measures that prove to be ineffective;
contribute to improvement of the equipment, mitigation, protective measures and best practices in environmental management.

By keeping these elements in mind, the determination of the EMSP’s project-specific objectives should derive directly from the objectives previously established during the environmental assessment of the project. The environmental assessments serve to identify the special concerns that must be taken into consideration at this stage. For example, these concerns may be associated with the presence of a specific type of contamination provoking major fears in the population, the presence of a special-status wildlife species or human health considerations. In this last case, a drinking water intake may be present near the site. Such elements are generally identified by the interested parties (e.g., federal departments and agencies, and provincial ministries, environmental groups, etc.) and the concerns they raise may be motivated by social, political or economic factors.

Box A-3 of Appendix A gives examples of formulating objectives.

2.2 Development of Verifiable Impact Hypotheses (Activity 2)

The second activity in drafting an EMSP consists of developing verifiable impact hypotheses. This activity begins with the analysis of the various components of the project, such as the impact sources, stressors, ecosystems, receptors and the apprehended responses (section 2.2.1). This analysis seeks to identify the impact mechanisms to be controlled and leads to the drafting of a conceptual model of the situation under study, by clearly establishing the cause-and-effect relationships (direct or indirect) (section 2.2.2). The development of a conceptual model makes it possible to better apprehend the problem by considering the level of uncertainty associated with the anticipated effects on the environment. This model results in verifiable impact hypotheses (section 2.2.3).

It is important to remember that the design of the sampling plans or programs of any EMSP must be based on hypotheses that anticipate the probable responses of environmental components to changes in the environment. The effort that must be devoted to this stage will depend on the comprehensiveness and the level of knowledge provided by the environmental assessment of the project.

2.2.1 Identification of the Components of the System under Study

The identification of the components of the system under study requires a precise knowledge of the activities of the dredging and/or sediment management project, and their interactions with all the environmental components. It is based on a compilation and analysis of the available information specific to the site or related to the problem under study:

preliminary analysis of information: the analysis of the site-specific data is based on the site maps and plans, the characterization data, the impact matrix produced during the environmental assessment and any other relevant documents. The analysis of the information obtained from similar projects conducted previously can also prove very useful at this stage of drafting of the EMSP.
critical examination of the data gathered: the critical examination of the data is intended to reveal possible deficiencies and biases in the available data in order to define the need for additional data and the means of obtaining it. This examination must be performed by taking into account the impact sources, stressors, ecosystem components, receptors and the apprehended responses (see Box A-4 of Appendix A).

2.2.2 Drafting the Conceptual Model

A conceptual model is a tool for describing the links among the physical, chemical and biological variables of the ecosystems, the resources at risk and the expected changes attributable to a given project or to natural causes. As an outcome of the critical examination of the data carried out during the previous stage, the conceptual model is meant to be a schematization of the stressor migration mechanisms in the ecosystem after changes (expected) resulting from the implementation of the project. It must also specify the scientific limits surrounding the schematized mechanisms. The understanding that results from a well-developed conceptual model allows verifiable impact hypotheses to be formulated, which can subsequently be tested.

Based in particular on the impact matrix of the project’s environmental assessment, the conceptual model is drafted by analyzing the sources of stress and the ecosystem elements. This analysis must be carried out according to a spatial and temporal framework that is consistent with the impacts to be verified. Box A-5 of Appendix A gives an example of an impact assessment matrix for dredging and sediment management projects. Box A-6 presents analytical elements for drafting the conceptual model.

The conceptual model describes how the stressors can affect the receptors. It can be simple and represented by a single schematic diagram. It can also be presented in the form of an impact matrix, a diagram or a summary table. For dredging activities, the conceptual model can be drafted in two parts. The first part presents the situation during the dredging activity and the second presents the situation after the dredging activity. Figure 4 shows an example of a simple conceptual model presented in the form of a schematic diagram.

Appendix C presents examples of conceptual models presented in tabular form. Table C-1 is an example of a conceptual model applicable to the dredging site during the work. In this example, the dredged sediments resuspended or lost during dredging cause a physical disruption of the environment and are one of the stressors related to the dredging activity representing the source. These suspended sediments are transported by different mechanisms to one of more of abiotic ecosystem components affected by the disruption. In a dredging context, the resuspended sediments are mainly directed to the water column; the hydrodynamic conditions determine their dispersion in the environment. The receptors exposed to the stressor through the targeted abiotic component must be enumerated. The apprehended responses must also be identified.

The distinction between the mechanisms governing the stressor (resuspension or loss in the bucket) and those governing the ecosystem (hydrodynamic conditions) make it possible to target the aspects inherent to the source and those inherent to the environment. This understanding is necessary for drafting the EMSP characterization plan (section 2.3).

Table C-2 presents an example of a conceptual model applicable to the dredging site after completion of the work. The sediments resuspended during dredging are therefore dispersed and deposited and the environment in which the sediments were dredged becomes a new

environment. The environmental component mainly affected by the dispersed sediments remains the water column, but the ecosystem now being targeted is different because of this dispersion of suspended materials, which is dependent on hydrodynamic conditions. The receptors and targeted ecological entities therefore also change.

Tables C-3 and C-4 present examples of conceptual models for sediment disposal in open water, while tables C-5 and C-6 propose examples of conceptual models for capping contaminated sediments. Other examples, including for containment in a riparian or terrestrial environment, are also presented in Appendix C. These examples are not exhaustive and obviously do not apply to all dredging projects. However, the aspects covered in these examples are an adequate basis for drafting conceptual models dealing with similar activities.

2.2.3 Formulation of Verifiable Impact Hypotheses

The conceptual model must lead to the formulation of explicit hypotheses that will optimize the development of the characterization plans and, more specifically, the selection of the assessment parameters. These hypotheses must describe the potential impacts of the dredging and/or sediment management project. In general, the statement of the spatial and temporal limits, in the formulation of a verifiable impact hypothesis, allows these limits to be circumscribed in the surveillance program or in the follow-up program. Drafting conceptual models in terms of activity and time limit, both during and after the activity, makes it possible to target three types of verifiable impact hypotheses:

those that exclusively require surveillance;
those that exclusively require monitoring;
those that require surveillance and monitoring.

Ideally, the formulation of a verifiable impact hypothesis should include the following six elements, based on the conceptual model:

sources and/or stressors;
the conversion or transportation mechanism;
the spatial limits and the environmental (abiotic) components targeted;
the temporal limits;
the receptors;
the apprehended negative responses.

The impact hypotheses may arise directly from specific concerns identified during the environmental assessment (or the assessment of the application for a permit or a certificate of authorization). However, depending on the project, the specificities of the site, the technology used and the progress of knowledge, several other impact hypotheses resulting from the drafted conceptual model can be added. Examples of verifiable impact hypotheses in relation to the conceptual models are presented in Appendix C.

2.3 Drafting the Physical, Chemical and Biological Characterization Plan (Activity 3)

This activity seeks to identify the descriptive tools required to verify the previously formulated hypotheses. It therefore specifies the technical and scientific means required to verify the hypotheses that will be the object of surveillance or monitoring. This stage must allow selection of the assessment parameters (section 2.3.1) and the related measuring parameters (section 2.3.2). It must also allow selection of the data analysis and interpretation modes and targeting of the action thresholds (section 2.3.3) based on the outcomes obtained. Table D-1 of Appendix D gives examples illustrating the different constituents of the characterization plan.

The drafting of the characterization plan must be based on a sufficient quantity of reliable data to be able to make the right decisions with an acceptable error rate (false positives and false negatives), while limiting the data acquisition effort to a minimal level (all the necessary data but only the necessary data). This process is summarized in the sections below and described in the following documents: USDE (1994), USACE (1994), USEPA (2006) and CEAEQ (1998).

2.3.1 Selection of the Assessment Parameters for Monitoring and Surveillance

The assessment parameters are a set of variables evaluated in order to test the verifiable impact hypotheses. These parameters must be clearly and precisely defined. It may be necessary to monitor several of them to validate a single hypothesis. One or more assessment parameters are selected by examining the set of receptors specified in the conceptual model and by answering the following questions:

Is the assessment parameter significant in relation to the hypothesis to which it pertains?
Is the assessment parameter appropriate to the phenomenon and the problem under study?
Is the assessment parameter measurable or estimable?

Note that the spatial and temporal limits established in the conceptual model must also be taken into consideration.

Since several assessment parameters can be defined for the same verifiable impact hypothesis, it may be relevant to use assessment approaches that include a set of measurement parameters. In this first stage, these approaches, generally based on assessment of the weight of the evidence, must be considered in drafting the characterization plan in order to facilitate selection of the assessment parameters and the measurement parameters associated with them (see Menzie et al., 1996; CEAEQ, 1998). An example of the link between the verifiable impact hypothesis, an assessment parameter and a set of measurement parameters for a dredging project is provided in Table D-2 of Appendix D. This example posits the hypothesis that sediments will be resuspended in the water column during dredging operations, reach a spawning site located downstream from the work site and significantly affect this site’s potential. To verify this hypothesis, it is considered that the resuspended sediments will reach the spawning site located 5 km from the work site and that they will significantly affect yellow perch breeding (assessment parameter). To verify this assertion, suspended particulate matter (SPM) and turbidity (physical measurement parameters) will be measured at the work site and at the spawning site, where researchers will also verify clogging and the effect of SPM on fry survival (biological measurement parameter).

2.3.2 Selection of the Physical, Chemical and Biological Measurement Parameters

The measurement parameters are measurable descriptors associated with the assessment parameters and which allow verification of these parameters (see Table D-3 of Appendix D). Several measurement parameters are often required for a single assessment parameter. There are:

physical measurement parameters: description of the physical properties of the stressor (solid, liquid, gaseous, particulate, size, surface type, etc.) and the ecosystem (hydrodynamic, temperature, etc.);
chemical measurement parameters: description of the chemical properties of the stressor in terms of interaction and concentration in the environment;
toxicological measurement parameters: description of the disruptions related to the toxicological response selected for the assessment parameter;
biological measurement parameters: description of the characteristics of the receptor in terms of biological or ecological entities.

As a general rule, the measurement parameters are linked to relational tools that allow a connection to be made between the information generated by the measurement parameters and the assessment parameter to which they are associated. For example:

extrapolation between taxa: toxicity data on a substitute species extrapolated to a species that is present in the target ecosystem;
extrapolation between responses: acute toxicity data extrapolated to a chronic toxicity effect;
extrapolation from the laboratory to the targeted ecosystem: effect on a species measured in the laboratory extrapolated to an effect in the target ecosystem for the same species;
extrapolation from an ecosystem to the target ecosystem: data observed in related studies, extrapolated to the ecosystem under study;
estimation of indirect effects: deductive methods, such as an event tree or a trophic network model;
estimation of the fate of the stressor in the target ecosystem: dispersion estimation of the stressor in the environment;
estimation of concentrations in environmental compartments: modeling of concentrations in aquatic organisms based on concentrations in the water.

The characteristics of the relational tool are determining factors in the selection of the associated measurement parameter. It is therefore appropriate to select the “measurement parameter/relational tool” combination as needed to verify the assessment parameters, that is:

the level of effort to be provided based on the acceptable level of uncertainty/precision;
the time required to obtain results;
the sensitivity of the “measurement parameter/relational tool” combination.

The surveillance activity requirements may be different from those related to monitoring activities. Surveillance activities generally require obtaining results rapidly and a sensitivity of the “measurement parameter/relational tool” combination, in order to adequately prevent the environmental impacts by implementing the contingency plan in timely fashion (section 2.4). Monitoring activities, on the other hand, are generally more focused on the accuracy of the assessment.

2.3.3 Determination of the Action Thresholds

To respond effectively during monitoring and surveillance activities, action thresholds must be established in advance for each of the assessment parameters chosen. These thresholds are usually defined on the basis of standards, criteria and guidelines pertaining to environmental protection legislation and regulations. They can be defined on the basis of other issues identified during the environmental assessment or public consultations on the project. The assessors’ professional judgment also plays an important role. Table D-4 of Appendix D presents a summary of the main legal tools used in Quebec for dredging and sediment management projects. These tools may prove useful for establishing action thresholds.

In the absence of fixed standards or criteria for certain assessment parameters, the ecosystem reference state, assessed at the work sites, or the state assessed at regional reference stations, may be useful for establishing action thresholds.

In order to decide how to integrate the action thresholds associated with each of the assessment parameters used as management tools within the context of the EMSP, it is essential to have a clear understanding of the bases for their establishment. It is also important to establish, for each assessment parameter, a level of precision that will make it possible to judge whether or not the action threshold is exceeded. Additional information on this subject can be obtained in the following documents: USDE (1994), USACE (1994), USEPA (2006) and CEAEQ (1998).

2.3.4 Determination of the Quality Assurance and Quality Control Program

Quality assurance and quality control programs (QAQCP) consist of a set of internal and external practices of an administrative and technical nature; these are intended to ensure the quality of the data generated by the EMSP in terms of precision, accuracy, detection limit, reproducibility, etc. QAQCPs also make it possible to ensure that the data is used as intended (CEAEQ, 1998; Martel et al., 2002). The quality control process seeks to prove that the data gathering and analysis activities meet the predetermined quality objectives. The goal of quality assurance is to verify the effectiveness of the quality control program. Any environmental sampling and analysis program, particularly those geared to verification of a project’s impact assumptions, must include a QAQCP.

The quality objectives of the data must be established according to the following principles:

produce good quality data by means of standardized and recognized sampling techniques;
capture the natural spatial and temporal variability of the ecological indicators;
be sensitive to sample contamination and the presence of extreme values due to the natural or special conditions of disruption sources;
supply complete documentation and ensure reliability of all data.

In order for the data produced to be documented in a way that enables an unequivocal evaluation of the outcomes, each EMSP must define an analytical QAQCP that corresponds to its needs. Such a program must cover the following elements:

quality assurance objectives (precision, accuracy, detection limit, data comparability, etc.);
sampling and sample processing methods;
custody, transport, conservation and storage of samples;
calibration methods and calibration frequency;
analytical protocols and experimental approaches;
reference and quality control standards;
reference documentation;
data validation, verification and presentation;
internal audits for quality control;
preventive maintenance methods and schedule;
specific methods to use for current assessment of data quality;
corrective actions;
quality assurance reports presented to management;
references.

2.3.5 Selection of the Data Interpretation Methods

Generally, several measurement parameter/relational tool combinations are considered for a single assessment parameter. Selection of the data processing methods represents an important step for subsequent interpretation of the outcomes. This selection is largely modulated by each of the choices made during the previous steps of drafting the characterization plan.

When selecting the modes of interpretation of the outcomes, it is important to remember that the purpose of the analysis is to establish the extent to which the forecasts are accurate or confirmed by the data generated by the EMSP. For digital data, statistical data processing methods are generally used. Other data integration approaches are proposed in the literature. The selection of the data interpretation method must take account of the limits of each approach (Chapman, 1986; Menzie et al., 1996; USEPA, 1992a; 1992b).

2.3.6 Drafting the Characterization Plan

The outcome of all the actions performed to date in Phase I of the EMSP is the drafting of the characterization plan (sections 2.1 to 2.3). This plan specifically concerns the activities that must be performed to acquire the necessary data for the achievement of the EMSP’s objectives. It must, at a minimum, include the following elements (described in more detail in Appendix E):

selection of the sampling stations;
determination of the number of samples;
establishment of the sample collection frequency;
selection of field and laboratory analysis methods;
identification of the shipping procedures and sample conservation modes;
selection of sampling equipment and procedures;
establishment of the quality assurance and quality control program (QAQCP);
establishment of the occupational health and safety program.

The scope of the characterization plan depends on the nature and volume of the sediments to be dredged or managed, the duration of the operations, the areas affected by them, the technologies selected for the performance of the work, the sensitivity of the receiving environment and the level of precision sought, depending on the EMSP’s objectives. At this stage of the EMSP, it is necessary to establish the basis of comparison between the actual effects of the operations and the anticipated effects. For this purpose, data must be obtained that will allow the establishment of reference points attesting to the original site conditions prior to initiating the project; this will allow an adequate assessment of the future changes.

2.4 Drafting the Contingency Plan (Activity 4)

Every EMSP must have a contingency plan. The plan defines the management options by forecasting the actions to be taken based on the outcomes obtained during monitoring and surveillance. For example, if the outcomes show that the project produces effects beyond the predetermined action thresholds, it is important that the proponents/managers have a contingency plan that defines the conditions of response and the way to apply them rapidly. In addition, if the surveillance and monitoring performed according to the characterization plan make it impossible to verify whether or not the action thresholds are exceeded, an adjustment must be made.

The two triggering factors of the contingency plan are as follows:

recognition that the action threshold is exceeded for an assessment parameter;
the inability to affirm or invalidate, within the limits of the outcomes obtained and with an appropriate confidence level, that the action thresholds are exceeded.

The contingency plan must provide for the sequence of actions as soon as it is triggered. These actions must be arranged logically within a decision tree that specifies the persons responsible for each action and the decision-making process. The scope of the contingency plan must match the scope of the EMSP to which it is associated.

Two non-exclusive action categories can be set in motion when the contingency plan is triggered:

1. Modification of the EMSP during performance: Two cases can lead to the modification of the EMSP as initially drafted: the need to reduce the uncertainties due to an assessment or measurement parameter or the detection of unforeseen impacts. To better circumscribe the uncertainty regarding the assessment of the project’s actual impacts, modification of the EMSP may consist of:

addition of assessment parameters;
addition or modification of measurement parameters;
addition or modification of sampling stations;
addition of samples;
modification of sampling methods;
modification of sample analysis methods.

2. Establishment of new mitigation measures: This action makes it possible to reduce the project’s actual impacts when the predefined action thresholds are exceeded. The mitigation measures were defined during the environmental assessment stage of the project. However, in the event that certain mitigation measures established before or during the operations prove to be ineffective or that unforeseen impacts occur, it might be appropriate to apply additional mitigation measures. Appendix F presents examples of mitigation measures that apply to different sources that could have an impact on the water column or the terrestrial environment.

When planning mitigation measures, it is important to ensure that they are technically, logistically and economically feasible and that they can be put in place quickly. Scenarios using alternative measures must also be anticipated to attenuate unforeseen situations. Mitigation can be effective on several levels:

Source: reduction of the scope (duration, volume, nature) of the activity.
Stressor: establishment of methods aimed at reducing the presence of the stressor or eliminating it, such as the use of a more effective technology.
Ecosystem: establishment of methods aimed at reducing the source when certain ecosystem-specific mechanisms risk dramatically increasing the stressor’s effects, such as a reduction of dredging activities during adverse hydrodynamic conditions.
Receptor: establishment of systems allowing reduction or elimination of exposure of receptors to the stressor, especially for sensitive receptors.
Apprehended response: establishment of methods allowing elimination of the apprehended response of certain receptors to the stressor or establishment of compensatory measures, such as the enhancement of habitats to ensure that there will be no net habitat loss.

2.4.1 Emergency Preparedness Plan

An EMSP’s contingency plan should include an emergency preparedness plan. It should be designed to identify the main actions to be taken in case of an incident or accident during the project and to specify the warning transmission mechanisms. The way the emergency preparedness plan is integrated with those of the municipalities concerned must also be specified. Box A-7 of Appendix A presents the elements of a typical emergency preparedness plan proposed by the Ministère du Développement durable, de l’Environnement et des Parcs du Québec (MDDEP, 2003a; 2003b; 2005; 2007). The instructions contained in the emergency preparedness plan must be an integral part of the awareness and training program for the employees who work on the different sites (see section 3.4).

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