Progress on establishing and implementing an EMS to support the WD SDS has been hampered by lack of dedicated resources.

WD requires an increased internal capacity to ensure the infrastructure to support sustainable decisions for WD operations, products and services are delivered.

• Establish a SD Team consisting of representatives from different parts of the organization.
• Perform a Gap Analysis for EMS (Completed: July 2000)
• Implement changes to EMS based on results of Gap Analysis (Completed: August 2000).
• Appoint an EMS manager

SD issues were not identified in the 1997 SDS.

A procedure for identification of SD issues is an integral first step in the SDS planning phase. This process ensures that all relevant SD issues are addressed under our SDS.

• The procedure for performing the SDS Issue Scan has been established. This procedure requires WD to review and revise its SDS issues on a regular basis during SDS consultations with stakeholders and employees.

Lack of identification of training needs of WD personnel with respect to the SDS and EMS.

Employees must be made aware of their responsibilities and how those responsibilities contribute toward sustainable development initiatives and improved environmental performance.

• Establish a procedure to ensure that WD employee training and awareness requirements are met.
• Perform a training needs analysis.
• Based on results of training needs analysis, develop a Training and Awareness Plan of Action to ensure that SD awareness needs are met.

A number of targets in the 1997 SDS Action Plan were not met, and appear as "On-going" in the SDS (1998-2000) Action Plan Progress Update. A few 1997 "initiatives" have been dropped or downgraded. The "Measures" suggesting numeric performance indicators included in the 1997 SDS Action Plan are not included in the SDS (1998-2000) Action Plan Progress Update.

As numeric targets were not set, the overall level of accomplishment is difficult to judge. The ’97 SDS may have been overly ambitious (22 targets) given available resources.

• Develop a procedure describing how goals, objectives and targets are established.
• Revise objectives and targets based on issues, aspects and impacts identified through implementation of EMS procedures and results of SDS consultations. Targets shall be time-bound and measurable.
• Establish environmental action plans for achieving each objective and target. These plans shall outline due dates, responsibilities and resources.

A process does not exist for monitoring, measuring and reporting on the achievements of sustainable development and environmental performance.

Based on the fact that "what gets measured, gets done", WD needs to establish an Environmental Performance Measurement Framework. This framework will establish processes for measuring, analyzing and reporting on the achievement of our objectives and targets.

• Establish a procedure for monitoring and measuring achievement of objectives and targets through the establishment of performance indicators.
• Establish a procedure for ensuring that WD’s environmental performance is reported, communicated to employees, stakeholders on a regular basis and included in the annual Departmental Performance Report.

Lack of a process for Corrective Action.

Our strategy is based on the concept of continual improvement. In order to ensure that we correct what goes wrong we must have a system to identify problems and ensure that action is taken to correct them.

• Establish procedures for corrective and preventive action. Ensure that all corrective actions are presented at each management review.

Lack of a process for senior management review of SDS and EMS direction.

A process must exist by which senior management is regularly informed of the status of the SDS and EMS performance.

• Establish a procedure for regular review of the performance by senior management.