Environmental Compliance Management
To achieve the project's environmental goals, an independent environmental compliance team reviews design and monitors construction to achieve maximum avoidance and minimal impact on the environment.
Environmental Management Systems for Design-build Infrastructure
As development projects get bigger and environmental laws grow more complex, the job of keeping a project in full compliance (and out of the papers) becomes ever more challenging. That is why those responsible for executing major infrastructural and development projects are increasingly turning to environmental compliance specialists – like Hicks & Company – who can apply systematic management techniques to keep environmental risks under control.
Hicks & Company’s environmental compliance specialists have pioneered the application of environmental management systems (EMS) to large scale construction projects, with emphasis on the particular requirements of fast-moving design-build projects. On TxDOT’s SH 130 project – the first design-build highway project in Texas – Hicks & Company environmental managers have developed a program that has received national attention for its innovations in the field of construction-related EMS.
Environmental Management System
To achieve the project's environmental goals, an independent environmental compliance team reviews project designs and monitors construction to achieve maximum avoidance and minimal impact on the environment. The team includes wetlands and wildlife biologists, land use planners, archeologists and architectural historians, water quality, hazardous materials and traffic noise specialists.
The functions of the environmental compliance team are implemented through an Environmental Management System (EMS) designed to achieve the project's environmental objectives through careful planning, implementation and operation. The EMS calls for an environmental protection training program for all employees, as well as execution of procedures developed to guarantee compliance. Part of the EMS calls for the development of certain tools, such as the Project Mitigation Plan and the Construction Monitoring Plan which provide the basis for sound environmental management throughout the duration of the project.
Environmental Compliance Inspectors (ECI) monitor all construction activities to ensure protection of sensitive resources and compliance with applicable environmental regulations and permits. Daily monitoring logs are compiled into weekly reports that are reviewed by a multi-tiered environmental management team. Both TxDOT and LSI environmental personnel will conduct spot checks of construction activity to ensure proper coverage of all areas. This system is guided by the underlying principle of continual improvement.
Comprehensive Services
Hicks & Company’s environmental management professionals are experienced in designing and implementing compliance-focused EMSs for large scale infrastructural, industrial, and design-build projects. Compliance focused EMS's are especially adaptable to the requirements of large design-build highway projects, like those now proposed in many parts of Texas under Comprehensive Development Agreements of TxDOT or Regional Mobility Authorities (RMAs). In addition to designing and staffing fully functioning comprehensive compliance management programs, we can deliver or provide guidance on individual EMS components, including:
- Environmental commitments analysis: This task includes inventory and analysis of federal, state and local environmental laws, regulations, protocols, and procedures affecting the project or operation
- Gap analysis: a systematic review of existing programs and functions to ascertain where an organization’s structure complies with EMS protocol. Gap analysis helps avoid duplication and ensure integration of existing management assets into the system.
- Development of system materials: including plans, field guides, manuals, procedures, and SOP's, prepared in collaboration with client staff to provide the basic documentation of the EMS
- Training: includes the development and delivery of training and orientation programs for the client’s environmental staff in implementing the EMS, and for operational staff in assuring good overall environmental performance. Services include the development of training materials in multimedia formats (videos, power point, web-based manuals).
- Environmental quality control: especially important in fast-moving design-build projects, this includes review of intermediate and final designs to ensure conformity with all applicable environmental legal requirements and policies, and implementation of parcel clearance procedures to provide that all important last check before actual construction begins
- Compliance-related support investigations and documentation: also critical in the design-build environment, these services may include archeological surveys, historic properties research, wetland delineations and permit modifications, hazardous materials investigations, and habitat assessment and mitigation support. These services and promptly produced reports and documentation can be critical to keeping a project on schedule in the face of changes in design, right-of-way, or other circumstances and incorporate adaptive management practices that assists an organization’s EMS required element of continual improvement.
- Evaluation and audit: Good performance requires periodic assessment and reporting on EMS operations, with emphasis on practical diagnostic recommendations.
- Monitoring and inspection: this includes occasional or long term compliance monitoring services focused on SWP3, hazardous materials, Section 404, NEPA, cultural resources, and other regulatory requirements. We can also assist in the creation of monitoring checklists and metric measurement systems.
- Compliance-related data management systems: information specialists can develop new systems or adapt existing systems to address EMS record-keeping and documentation requirements.
For more information on Hicks & Company’s compliance management
and EMS-related services, contact:
Tom Van Zandt: 512-844-6299
Jim Robertson: 512-478-0858
Melita Elmore: 512-217-7887
Jason Buntz: 512-844-0977
National interest in SH 130 EMS
EMS innovations developed for the SH 130 design-build project have proven to be of interest in a number of highway and environmental forums and media outlets around the country. Hicks & Company EMS staff have given papers and presentations at, among others:
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April 28, 2004. Austin, Tx.
Presentation: Environmental Issues & Permitting Pitfalls: SH 130 Compliance Management and EMS
Austin Contractors & Engineers Association (ACEA) Central Texas Design and Construction Symposium -
May 4, 2004. Austin, Tx.
Presentation: The Value of Community Involvement in the EMS: the Case of SH 130
TCEQ Environmental Trade Fair/Clean Texas Conference -
October 13, 2004, College Station, Tx.
Presentation: SH 130 EMS and Adaptive Management
TxDOT Short Course -
December 1, 2004, Austin, Tx.
Presentation: SH 130: EMS, EPICs, and Adaptive Management
TxDOT Environmental Coordinators Conference -
January 10, 2005, Austin, Tx.
FHWA Staff Symposium
Presentation: SH 130 EMS: Integrating NEPA, EPICs and Adaptive Management -
February 2005, Austin, TX
Central Texas Semi-tech Conference
“A Case Study in EMS: SH 130“ -
March 2005, Omaha, Nebraska
Western Association of State Highway Transportation Officials (WASHTO)
“EMS Applications in a Design-Build Environment” -
April 8, 2005. Austin, Tx.
CLE International: National Environmental Policy Act (NEPA) Conference
Presentation and Paper: “Resource Assessment and NEPA Integration: Energizing NEPA’s Performance Capabilities through Adaptive Environmental Management Systems” -
April 8, 2005. Austin, Tx.
American Society of Civil Engineers (ASCE), Texas Section, Conference, SH 130 Super-track
Paper: “EMS Applications in a Design-Build Environment” (with Melita Elmore and Jason Buntz) -
April 11-14, 2005, Chicago
EPA National Environmental Partnership Summit
Presentation: “NEPA Integration and the Adaptive EMS: Lessons from a Design-build Highway Project” -
April, 2005, Tampa, Fla
Joint Services Environmental Management Conference
“EMS and NEPA” -
June 1-3, 2005, Philadelphia
EPA Green Highways Forum
Presentation: “The Adaptive EMS in a Design-build Environment: Notes from State Highway 130 in Central Texas” -
June 2005
Associated General Contractors Environmental Observer Newsletter -
Summer 2005
AASHTO Environmental Successes Website -
July 2005, Charlotte, N.C.
Transportation Research Board: Environmental Stewardship in Transportation
Presentation: “The Adaptive EMS in a Design-build Environment: Notes from State Highway 130 in Central Texas”
Video Footage - Owl Rescue and Release
LSI inspectors found an abandoned great horn owl on the ROW for the SH 130 project. Permitted to rescue abandoned or injured birds, the Hicks team took the baby owl to a wildlife rehabilitation specialist, where it was raised with 3 other rescued owls. The owl, nicknamed Bounce, spent over 6 months learning how to hunt and survive before being released into the wild by the highway project.
Video Training Program - Water Quality Module
As part of the EMS, Hicks & Co developed a series of video training programs, addressing the natural resources and environmental issues that could be impacted by construction of the highway. Each worker on the project must have a minimum level 1Environmental Overview training; supervisors, foremen and managers undergo a more intensive 5 hour training. The video shows a clip from the Water Quality module (other modules include Overview, Cultural Resources, Ecology and Hazardous Materials).


