Version No: 1
Issue Date: May 15
Review Date: May 16
GUIDANCE ON PREPARING
CONSTRUCTION
ENVIRONMENTAL
MANAGEMENT PLANS
Technical Authority: ASEE
Subject Matter Expert: DEPA
Purpose of this Document
This document provides guidance on the minimum requirements for preparing a
Construction Environmental Management Plan (CEMP) for projects either occurring
on the Department of Defence (Defence) estate or at the direction of Defence.
Whilst providing direction on content and matters for inclusion, the document is not a
template. Defence recognises that the scale, complexity and local environment of
different projects will alter the coverage of issues and level of detail required within a
CEMP. This guidance document is therefore intended to assist with the development
of consistent, effective and easy to use EMPs that uphold commitments and
conditions of approval made throughout the environmental impact assessment
process.
What is a CEMP?
A CEMP is a site or project specific plan designed to ensure best practice and/or
appropriate environmental management practices are applied throughout the
construction, operation and/or demolition phases of a project.
The production of a CEMP constitutes a critical step in the environmental impact
assessment process used by Defence to identify and avoid, mitigate or offset the
impacts of its actions on the environment. CEMPs must nominate specific measures
to address:
 the likely environmental impacts and necessary mitigation measures that
have been identified throughout the impact assessment process (as
summarised in the Environment Assessment Report (EAR) produced by
Defence for larger projects);
 any conditions of approval associated with a project – this will include the
EAR and any conditions imposed by the Minister for the Environment if the
project was referred under the Environment Protection and Biodiversity
Conservation Act 1999; and
 all other matters bought to the attention of the contractor by Defence staff
including Regional Environment and Sustainability Officers (RESOs) or
regional Assistant Directors Environmental and Sustainability (ADESs).
What information does a CEMP need to contain?
The CEMP must contain at least the relevant information outlined in this guidance
document.
While this document will guide the scope of the CEMP, it should not be seen as
exhaustive or limiting as each project has its own specific set of circumstances.
Matters not addressed in this guidance document that are found to be relevant to a
CEMP must be included.
CEMPs are part of the broader environmental management documentation for an
organisation and/or project. Accordingly, the CEMP should not be prepared in
isolation – it must incorporate key elements of the environmental impact assessment
process for the project (a requirement of Defence’s environmental management
system) and the construction organisation’s own environmental management system.
When should a CEMP be prepared?
Ideally, the preparation of a CEMP commences during the detailed design phase of
project planning. This allows both processes to influence the other. Where this is not
possible – if a contract for the project has not been let – the Defence Project
Management Team should maintain a brief on any issues that emerge that should be
covered in a CEMP and provide this information to the successful contractor.
Projects that will or may have adverse environmental impacts that are not managed
under other Defence Orders, Instructions or procedures will need an approved
Environmental Clearance Certificate (ECC) from Defence prior to commencement. A
CEMP is typically submitted with an ECC application by the construction
organisation. If a CEMP is not submitted, the approval of the CEMP will become a
condition of the ECC issued by Defence. Either way, an approved CEMP must be in
place prior to the commencement of works. The time taken to obtain an ECC from
Defence RESOs or ADESs will be closely related to the quality and completeness of
information provided to them in the initial CEMP document. Projects requiring an
ECC will not obtain approval without a valid CEMP.
Consultation
The environmental impact assessment for a project may not describe particular
environmental impacts or their control measures in sufficient detail to fully inform a
CEMP. CEMPs operate on the principle of quality assurance – plan, check, review
and improve – so where this situation arises, consultation between the contractor,
Defence Project Team and approval authorities such as the RESOs, ADESs and the
Directorate of Environmental Protection and Assessment (DEPA) will be required.
CEMP review
CEMPs are not static documents. They require updating during the course of a
project to reflect new information and alterations to environmental controls. Reviews
must be undertaken when:

approval to commence works associated with the project is granted by an
ADES, RESO or DEPA in the form of an ECC. Conditions attached to that
approval typically mean the contractor must update their CEMP to comply
with the conditions; or

there is a change in project scope (that relates to or may change the
environmental risks of the project and the controls in place to avoid or
mitigate those risks); or

an environmental incident takes place; or

an improvement is identified through either onsite experience, audit findings
or a change in industry best practice or standing legislation.
Changes required to CEMPs must be communicated to the RESO (or other relevant
approval authority). A RESO may require re-submission of the CEMP for approval
where changes introduce new potential environmental impacts, alter the frequency or
consequences of existing impacts or may result in a significant environmental impact.
The Do’s and Don’ts of a CEMP
Do:
 Prepare the CEMP in a manner that makes it useful on site – especially for
construction personnel implementing both the works and mitigation measures
e.g. include site plans and dot point instructions
 Do contact the RESOs relevant to your project when preparing your CEMP to
discuss the project. Contact details are available through your Defence
Project Manager.
 Do submit to the RESO a CEMP that has been critically peer reviewed by an
independent party.
 Do provide a CEMP that is as concise as possible without omitting critical
information.
 Do include all of the sections outlined in the CEMP content guidance below.
Obviously the scale, complexities and environmental surrounds of the project
will change the extent to which different sections are relevant.
 Do be mindful that a CEMP explains aspects of actions undertaken on the
Defence estate and therefore may sometimes be made available to the
general public.
 Remember that CEMPs are not static documents – they will often require
updating during the course of undertaking the project.
 Use definitive language that commits to undertaking control measures. Terms
like ‘may’ or ‘should’ must be avoided. Use of non-committal terms will slow
down the review process and result in more conditions being placed on any
potential approval.
 State exactly how the project has tailored a company’s generic processes to
this specific project.
Don’t:
 Don’t submit a company or industry generic CEMP – it must be tailored to the
prevailing site conditions.
 Don’t complicate the CEMP by pursuing irrelevant or marginal issues.
 Don’t submit a CEMP that has large ‘cut and paste’ sections from previous
plans.
 Don’t leave out sections of the CEMP when submitting the document to
Defence. To avoid critical time delays, only completed CEMPs should be
submitted for RESO review.
CEMP Format
The overall size of a construction, as well as its complexity, timeframe, setting and
the number of sites involved can all influence the format of the CEMP most suited to
the task.
Defence does not mandate the use of any particular format for CEMPs. Below are
some notes on the more commonly used formats. Note that terminology in this
section is shared with the suggested structure and table of contents page.
Small Projects (e.g. small in area and no complex environmental issues)
Use either:

a template CEMP with supporting checklists tailored for the job (suitable for
contractors regularly undertaking similar projects with similar potential
impacts and controls regardless of the site involved). Much of the
Implementation section of the CEMP will take the form of checklists; or

a site based approach where environmental impacts and controls are
categorised and tabulated in the Implementation section of the CEMP for
each site included in the project; or

an issues based approach where impacts and controls are categorised by
the environmental issues involved. The Implementation section will typically
include a table for the impacts and controls associated with each
environmental issue. This approach works best on projects without distinct
stages or multiple sites.
Large Projects (e.g. multiple sites and/or complex environmental issues)
Use either:

a stage based approach where environmental impacts and controls are
categorised under each stage of the project (for example, setting out preconstruction, construction and post-construction phases in the
Implementation section of the CEMP); or

a combined issues, stage and site based approach where the large scale and
complexity of the project mean that the impacts and controls are better
described and made more accessible via a suite of environmental
management documents instead of a single CEMP. These documents may
include, as examples, a construction framework EMP (covering everything
except Implementation), issue specific sub-plans (which cover
Implementation) and site or activity related work method statements (which
will cover elements from Environmental Management, Monitoring and Review
and Implementation).
Defence Policy
Defence maintains environmental policies on the following environmental factors
potentially impacted by projects conducted on the Defence estate:

Biodiversity Conservation (including movement of wildlife)

Biosecurity, Feral Animals, Weeds and Overabundant Species

Bushfire Management

Contamination (including hazardous substances and chemicals)

Energy Efficiency

Ecologically Sustainable Development

Sustainable Procurement

Heritage (Indigenous and European cultural heritage)

Pollution Prevention

Soil Conservation (all aspects including stockpile management)

Waste Minimisation

Water Management

Unexploded Ordnances (UXOs) – protocols for finds/clearance protocols
These Defence policies are available through one or more of these sources:

the Defence Internet site
(http://www.defence.gov.au/estatemanagement/Governance/Policy/Environm
ent/Default.asp);

the Intranet site
(http://intranet.defence.gov.au/estatemanagement/Governance/Policy/Enviro
nment/Default.asp); or

the relevant Defence Project Officer, DEPA, ADESs or RESOs.
Where relevant to a project being undertaken by or on behalf of Defence, the
requirements for environmental protection within these policies must be upheld within
the CEMP.
Proponent’s Responsibilities
As a project proponent, you are responsible for ensuring:
 The information provided in your CEMP is complete and correct;
 You communicate the commitments made in the CEMP to your own staff and
all sub-contractors;
 You uphold the commitments made in your CEMP throughout the project.
Common Omissions from CEMPs
Defence has compiled a list of commonly overlooked issues in CEMPs relating to the
following environmental aspects. Whilst the issues are sometimes raised, providing
insufficient details on who, what and when will result in delays during the review
process and more lengthy conditions on any approval.
Sediment/Storm water protection and Pollution Prevention
 Design of adequate site specific erosion control features for surface water
runoff and identification in the relevant plan
 Protection of drainage inlets
 HAZCHEM storage areas (location, bunding, MSDS availability, spill
equipment, fire fighting equipment)
 Identifying re-fuelling areas and re-fuelling procedures, spill kit type and
location
 Stockpile management – sedimentation protection and rehabilitation
procedure at conclusion of works and during inactivity, siting, recommended
heights, types of material to be managed (e.g. topsoil/substrate), mulch (incl.
fire risk) and time for materials to be left in-situ.
 Construction septic system management – alarms and back-ups
 Procedure for encountering groundwater/dewatering process
 Controls for system tests that may go wrong, eg fuel hydrant pressure testing,
fire protection foam tests
Bushfire Management
 Fire response and prevention (identifying no hot works on days with a Fire
Danger Index of High or above, response procedures)
 Stockpile management if mulch/compost is used
Landscape and Vegetation Management
 Discussion on establishment period (and any rehabilitation after failure) and
any subsequent care required
 Suitability of stabilisation and cover crop species for natural areas vs
cantonment/urban landscapes
 Suitability of proposed species for use in Asset Protection
Zones/airfields/other areas with security requirements
 Intention to mulch or undertake other forms of stablisation/protection
 Protection of planted stock from feral or browsing species
 Tree protection procedures such as parking outside drip lines, tree
replacement rationale
 Clear identification of tree and vegetation removal requirements with clear
justification and inclusion of fauna spotters
 Timely submission and implementation of vegetation offset management
plans or other offset plans e.g. hollow log homes
 Weed management including restrictions on vehicles and designation of no
go areas
 Reporting process for sick/injured wildlife or discovery of unexpected habitat
Waste Management
 Management of airborne litter (especially in proximity to airfields)
 Routine clean up procedures and frequency
 Waste separation procedures and reporting on achievements (even if subcontracted) such as waste diversion from landfill statistics
 Process for providing waste receipts demonstrating disposal at licenced
facilities
Air Quality Management
 Dust suppression techniques and correlation to prevailing conditions (linkage
to wind speeds for example)
 Vehicular/machinery compliance with emission standards
Heritage Management
 Acknowledgement of any likely finds
 Chance find protocols (what will be done and is that consistent with a
Heritage Management Plan for the base/site?)
Contamination/Material Management
 Appropriate stockpiling methods in advance of offsite disposal
 Nomination of testing procedures to be followed in advance of offsite disposal
 Fire considerations when stockpiling materials
Noise
 Clear identification and justification for noisy tasks proposed to be undertaken
outside normal hours, including mitigation measures to reduce impacts
Light Pollution
 Consideration of direction and shielding in proximity to critical areas such as
airfields and residences
Training, Communications and Incident Management
 Inclusion of comprehensive induction course tailored to cover all relevant site
issues
 Inclusion of indigenous heritage training when there is potential for finding
artefacts (particularly for works occurring in culturally sensitive areas).
 Inclusion of the name and contact details for a 24/7 site contact.
 Clearly assigned responsibilities.
 Incident management and processes i.e. must articulate into Defence incident
reporting system
(www.defence.gov.au/estatemanagement/lifecycle/IncidentManagement/Envir
onment.asp)
 Contact details for State/Territory regulatory and response agencies such as
EPA, Fire Brigade.
Structure and Content of a Construction Environmental Management Plan
The structure of a CEMP is provided in a table of contents below. Details on how to
address each heading follow after this section. Whilst there may be additional
sections added by contractors this list is a minimum requirement.
PROJECT TITLE
ABBREVIATIONS AND DEFINITIONS
1 BACKGROUND
1.1 Introduction
1.2 Project description
1.3 EMP Context
2 ENVIRONMENTAL MANAGEMENT
2.1 Organisational Structure and Responsibility
2.2 Training, Awareness and Competency
2.3 Incident Response and Emergency Contacts
2.4 Communication
3 IMPLEMENTATION AND OPERATION
3.1 Establishing Environmental Risk
3.2 Environmental Activities and Controls
3.3 Environmental Management Plans or Maps
3.4 Management Schedules
4 MONITORING AND REPORTING
4.1 Environmental Monitoring
4.2 Auditing
4.3 CEMP Review
5 ATTACHMENTS
5.1 Site Map and construction footprint
STRUCTURE AND CONTENT OF A CEMP
Instructions for the users of this guideline are provided in green.
PROJECT TITLE
ABBREVIATIONS AND DEFINITIONS
1.1 Introduction
In this section, identify:
 The purpose of the CEMP and any project-specific outcomes intended
 Key players - the party that prepared the CEMP and will be responsible for
implementing and maintaining it.
1.2 Project Description
In this section, identify:
 Project background – briefly describe the Defence project that this particular
activity relates to including the major elements to be delivered under this CEMP.
 Project location – describe the location and include a site plan laying out the
major activities/facilities/compounds proposed
 Construction Activities - A description of the proposed works including:
o A brief description of the major construction processes to be used
o Normal working hours
o Type, frequency and duration of works conducted outside working hours
 Scheduling – include anticipated start and finish dates, including a break down
by stage if the project is to be constructed in stages.
1.3 EMP Context
In this section, identify:
 How the EMP relates to the planning process undertaken for the project as a
whole. Conditions from other approvals, licences or permits relevant to the
project will need to be described here to the extent they relate to the
management of environmental impacts associated with the site.
 Describe the relationship between this CEMP and any other environmental
management plans and sub-plans created for the project.
 Describe any environmental management requirements found in Head
Contracts and include a contractor’s response to them.
 Discuss relevant environmental legislation and policies applying to this activity
2 ENVIRONMENTAL MANAGEMENT
2.1 Organisational Structure and Responsibility
In this section, provide:
 An organisation structure (names, positions and contact details) of those people
responsible for the environmental management aspects of the project.
 Descriptions of the different environmental management roles undertaken by
those people.
 Descriptions of the same responsibilities and roles as they apply for subcontractors.
 Specific nomination of the position responsible for implementation and
maintenance of the CEMP.
2.2 Training, Awareness and Competency
All personnel working on site (including sub-contractors) must undergo a level of
environmental management training commensurate with their responsibilities under the
CEMP. Environmental training can take a variety of forms such as toolbox talks,
meetings or more formal training and should include:
 A site induction




Familiarisation with the requirements of the CEMP
Any specific training required for particular aspects of the project e.g. dust
management training for plant operators
Familiarity with site environmental controls
Emergency/incident response processes
In this section, identify:
 The training that personnel working on the proposed development will have
received (for example – general training identified above, specific training on
certain sub-plans etc.).
 The party responsible for ensuring that all personnel have received the
appropriate training.
 The location of records confirming who undertook which training events on
which dates and who conducted the training.
2.3 Incident Response and Emergency Contacts
In this section, identify:
 A contact person available 24 hours a day, 7 days per week who has authority
to stop or direct works and manage complaints
 Procedures to be followed in the event of an environmental emergency (any
event that causes or has potential to cause material harm to the environment)
 These procedures must include
o names and all-hours contact details for emergency response personnel
o the responsibilities of those personnel
o contact details for emergency services
o the location of on-site spill containment materials, Material Safety Data
sheets and other information on any hazardous materials present
o steps to be followed to minimise damage and control the emergency
o notification instructions and contact details for Defence and State/local
government agencies
NOTE – all environmental incidents must be reported to Defence via an AE444 web
form available at:
www.defence.gov.au/estatemanagement/lifecycle/IncidentManagement/Environment.a
sp
2.4 Communication
In this section, identify and expand upon aspects of your corporate communication
strategy relevant to the project such as:
 Internal communications
 Toolbox meetings
 Handling of external communications (incl. community liaison)
 Meeting minutes and memos
 Public complaints
 Community liaison
In all cases identify the person/s responsible for coordinating inputs, outputs and
actions arising from these communication aspects.
3 IMPLEMENTATION AND OPERATION
3.1 Establishing Environmental Risk
Defence recognises that there are a variety of risk assessment standards and
methodologies in use in Australia. Defence does not prescribe any one methodology
provided the following information is ultimately included in the CEMP:
 A list of the activities that are to be carried out during the project (including the




activities of sub-contractors and materials transporters)
Identification of the potential and actual environmental impacts associated with
those activities
Identification of which impacts are significant – using a methodology consistent
with existing environmental impact assessment documentation where possible
Use of this information to design the project’s environmental management
activities, controls and monitoring to prevent or minimise those impacts
Details on when and how often this risk assessment will be carried out/updated
NOTE – the risk assessment does not replicate or supersede the environmental impact
assessment or its findings or conditions of approval – it translates them into actual
construction or operational techniques relevant to the project.
In establishing the environmental risk associated with a particular project, a proponent
will need to make reference to the following documents containing information relevant
to their risk assessment:
 Environmental impact assessment documentation (Environmental
Reports(ERs), Environmental Impact Assessments (EIAs), contamination
investigations and other related studies or reports relevant to the project).
 Approval documentation such as assessment reports for the project and any
conditions of approval
 Detailed design reports
3.2 Environmental Activities and Controls (Aspects and Impacts Register)
A CEMP must specify all the environmental management activities, mitigations and
control measures that will be used to prevent or minimise environmental impacts.
These measures are to be grouped against the different environmental aspects that will
or may be impacted by the project. It should include the detailed mitigation measures
from the risk assessment. As this is typically the largest section of a CEMP it will be
attached as an appendix and is known as an Aspects and Impacts Register.
This section must:
 Identify which aspects of the environment at the site/s will be impacted by which
activities associated with the construction and assign control measures to
remove/reduce/offset those impacts
 Assign responsibility for control measures to specific personnel and assign
timeframes for their implementation
 Specify what monitoring is associated with each control measure
 Indicate what performance level or criteria is expected to be achieved for each
control measure (quantitative measures where possible)
 List any supporting documentation relevant to methodologies to be followed
during the activity (e.g. environmental handbooks/manuals for erosion and
sediment control, hazardous chemicals/substances, soil conservation, pollution
control, stormwater management and biosecurity – all during construction and
the Defect Liability Period)
3.3 Environmental Management Plans or Maps
Environmental control plans and maps are valuable reference tools on the project site.
They must be included in all CEMPs when relevant. These plans or maps must indicate
the location of the following:
 Environmentally sensitive areas both on and adjacent to the project site
 Waterways including drains
 Erosion and sediment control features
 Work areas, machine/vehicle parking, spoil stockpiles, material storage, wash




points and fuel and chemical stores
Vegetation requiring protection
Traffic restrictions/transport routes/direction of movement
Monitoring sites
Perimeter fencing
For projects involving multiple sites, these plans and maps will form a large part of the
implementation section of the CEMP when prepared for each site involved.
3.4 Management Schedules
Management schedules can be forms, registers or reports used during the day-to-day
management of a project. Relevant schedules must be included in a CEMP. Examples
include:
 Site Inspection Checklist
 Non-compliance and Corrective Action Report
 Complaint Report
 Environmental Incident Report
 Environmental Training Register
 Waste Register
4 MONITORING AND REPORTING
4.1 Environmental Monitoring
This section of the CEMP must explain how environmental management activities and
controls will be monitored. It may be beneficial to identify monitoring activities occurring
in each of the site establishment, construction, de-mobilisation and Defect Liability
Period phases. Monitoring should be conducted in accordance with the requirements
established within the Aspects and Impacts Register and/or any relevant environmental
sub-plans.
A monitoring checklist is required that specifies:
 When environmental control activities need to be carried out
 Who is responsible for carrying them out
 What methods will be used to measure effectiveness
 Space for sign-off to confirm the measure was undertaken and is working
 Any follow-up actions (such as non-conformance reports) and who is
responsible for them
Details on how monitoring records will be collated, distributed and stored should also
be included.
Where monitoring requires the use of technical equipment, also identify the approach
taken on equipment calibration.
4.2 Auditing
The CEMP should describe the process for periodic auditing of the plan’s
implementation and effectiveness.
The audit program and procedures should cover both internal and any external auditing
requirements. It should include the scope, frequency and methods, as well as
responsibilities and requirements for conducting audits and reporting results.
The frequency of auditing should be related to the inherent environmental risk
associated with the project – the more environmental aspects potentially significantly
impacted by the project the more frequent the auditing should be. Scope of the audits
should be guided by the findings of the risk assessment and whether project approval
conditions require compliance auditing.
The findings of the audit should be fed into the CEMP Reviews described at Section
4.3. Audit findings will also provide guidance on the rate of audit recurrence required.
4.3 CEMP Review
This section will describe how the CEMP will be reviewed, including looking at the
environmental management controls to ensure they are still relevant to the activities
being undertaken (a proposed change to the nature, extent or scope of activities
included in the project will trigger a CEMP review and resubmission to the RESO in its
own right). It must also include:
 When/how often reviews will be done
 Who will be responsible for reviewing the CEMP, recording decisions and
reasons for making them, and recording subsequent changes
 How the site/project team/RESO will be informed of those changes and their
implementation
 When the reviewed CEMP will be submitted to the approval authority (the
RESO).
References:

Elements of this guidance are adapted with permission from the Guideline for the
Preparation of Environmental Management Plans produced by the then NSW Department of
Infrastructure, Planning and Natural Resources, 2004 (© State of NSW through Planning and
Infrastructure).