The Limitations of EMSs in Comparison with the SDGs When Considering Infrastructure Sustainability: The Case of the Terzo Valico Dei Giovi, Italy

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The Limitations of EMSs in Comparison with the SDGs When Considering Infrastructure Sustainability: The Case of the Terzo Valico Dei Giovi, Italy


4.1. Terzo Valico Del Giovi

The case study selected for this article is the Terzo Valico dei Giovi-Nodo di Genova (TV). This was chosen because of its strategic importance in Italian infrastructure planning, because of the engineering scope of the work, and, finally, because one of the authors was hosted for a six-month research period at the environmental management offices of the general contractor: Consorzio Collegamenti Integrati Veloci (COCIV). The successful outcome of such a complex project depends on finding the compromise between the required construction performance, deadline, cost, safety, logistical constraints, and working conditions, always taking into account compliance with environmental regulations [78].
The TV is a railway infrastructure currently under construction. Its path extends between Genoa and Tortona mainly in a natural tunnel, with the primary objective of optimizing the connections of the Ligurian port system and improving the connections between northern Italy and central Europe (Figure 4).
The project includes the construction of 36 km of tunnels, out of the total 53 km of the line, with a total underground excavation that, considering accessory tunnels, reaches 88 km and a total production of muck equal to 16 million m3 [13]. The pass tunnel alone, with its 27 km, is currently one of the longest in the world; it crosses various geological formations, in a complex scenario linked to challenging geotechnical conditions and the presence of asbestos and methane gas [79].

The first procedures for the realization of the TV date back to 1991 with the start of the national policy for the construction of new high-speed railway lines. It was only in 2012 that the start of the works was achieved after years of denied outcomes through the EIA procedure; the completion of the works is scheduled for June 2025.

The infrastructure is realized by the COCIV consortium against an expenditure of EUR 6.9 billion, 3.4 of which comes from National Recovery and Resilience Plan [80] fund, is classified as a national strategic infrastructure [81], and is also included in the EU TEN-T policy [4] as the Mediterranean terminus of the Rhine-Alps corridor. The synergy that will be created between the Genoese port and the TEN-T will make it possible to maximize the growth in the commercial traffic expected thanks to the upgrading work being carried out in the Genoese port [78].
COCIV in the analysis of the strategies to be pursued since 2012 is assisted by the Environmental Observatory (EO), which consists of representatives from the Higher Institute of Health, ministries, regions, provinces, and the Regional Agency for Environmental Protection (Arpa) involved [82]. Moreover, to identify solutions capable of certifying the sustainable approach to the construction of the infrastructure, since 2018, COCIV has relied on the ISO 14001 standard and, since 2020, on the EMAS Regulation, with which it maintains control over the environmental impacts that the work generates on seven directives: air, water, waste, hazardous waste, soil, road, and noise.

COCIV, for TV, obtained EMAS certification to optimize business processes, reducing environmental impacts, effectively managing resources, and promoting dialogue with stakeholders. Based on the results shown by the environmental indicators, the protocol defines appropriate actions aimed at pursuing the principle of continuous improvement. The protocol pays special attention to relevant environmental aspects and related investments. The organizational context, stakeholders, performance indicators, and environmental targets complete the picture, providing an overview of environmental initiatives.

The EMAS protocol is subject to verification by the EO via Audit. EMAS identifies the Significant Environmental Aspects (SEAs) according to the type of work, and for each of which indicators are calculated to define any actions necessary to manage and mitigate them. Therefore, it is necessary to pursue a procedure for the identification of SEAs, the most important elements in an EMS [11], although at the same time, their definition represents one of the most problematic parts of the implementation of an EMS [83]. The EMAS regulation does not establish a method for assessing SEAs, but only provides some general guidelines [84]. The criteria on which they are defined must be comprehensive, susceptible to independent verification, and reproducible. These criteria may include issues related to material and energy flows, water resources, waste, biodiversity, emissions, as well as stakeholder opinions [47,49,84].
To identify the SEAs of the TV, COCIV follows a top-down process defined in the company’s environmental analysis. The first stage of the analysis delves into existing policies, specific risk elements, sector plans, and construction processes and encapsulates all within an Environmental Management Plan. The environmental risk aspects are organized in a summary table according to the work performed [13]. Each process is assessed individually against each environmental aspect by calculating the risk of generating a negative environmental impact. Following this procedure, SEAs are identified where a high risk is identified (Figure 5). The analysis considers all activities, even those not directly managed by the consortium, for reasonably foreseeable operating conditions and abnormal/emergencies. The perspective adopted covers the entire life cycle of the work, with a sensitivity relationship based on impact management efficiency, relevance, and sensitivity: vulnerability concerning the territory and stakeholder perception [13].
More particularly, the EMAS environmental statement addresses the management of excavated soil: of the 16 million m3, a part will be reused within construction sites and the majority will be used as a by-product for the environmental rehabilitation of former borrow pits [13]. Therefore, the management of these muck volumes presents economic and environmental challenges related to transport and storage to enable its reuse [85] while avoiding its disposal as waste. At the same juncture, the handling that takes place mainly via road vehicles is considered, for which emissions and fuel consumption are monitored [13]. An important additional challenge is the presence of natural asbestos along the route of the work. Consequently, a specific asbestos risk management protocol has been developed and approved to mitigate its possible impacts [86].

4.2. SDGs Evaluation on TV EMAS Protocol

After analyzing the adherence of the Envision protocol to the SDGs in Section 3.1, the same target-based approach was used in our case study to check the correspondence between the SEAs identified in the TV environmental statement and the SDGs.
To assess the alignment of the TV’s EMAS protocol with the SDGs, it is possible to use the significance table of environmental aspects [13], associating the SDGs with the 66 identified SEAs. The analysis was started by independently considering each of the areas identified in the rows of the table (Figure 5), concerning the associated or associable works. Similarly, to the operation carried out for the Envision protocol, the definitions of the 169 Targets that make up the SDGs were carefully examined to identify the underlying objectives. Subsequently, up to two SDGs were attributed to each SEA that were deemed to be predominantly pursued by comparing the TV-Targets SDGs.
The assignment was made considering the nature of the infrastructure and the impact of the operations on the areas being monitored, based on the in-depth studies in the EMAS protocol. In particular, the assignment of the SDGs was based on the analysis of the indicators defined in the protocol to monitor the effectiveness of preventive actions and to implement corrective ones. Where no specific indicators were defined, the attribution was based on the characteristics of the work and the area where the work is performed. To minimize randomness in the correlations, any indirect effects on areas related to other SDGs were not considered. The quantification of the weight of each SDG within the EMAS protocol provided for the assignment of one point for each SEA and, consequently, one point for each related SDG. In cases where two SDGs were assigned to a single SEA, the scores were distributed equivalently. Finally, the aggregation of the scores associated with each SDG made it possible to identify the SDGs pursued and their scope within the TV’s EMAS protocol. The analysis shows that nine SDGs with different emphases are considered in EMAS certification (Table 2).
The analysis shows that the SDG predominantly addressed is SDG 9, ‘Innovation and Infrastructure,’ with over 26% of the total, given the crucial role played in surveys, prospecting, and excavation and rehabilitation activities. This result is consistent with the nature of certification applied specifically to infrastructure works. Further considerations will be discussed in Section 6.2—SDGs in TV’s EMAS certification—as they are useful for comparison with the Envision protocol analyzed above.

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