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close this bookConducting Environmental Impact Assessment in Developing Countries (United Nations University, 1999, 375 p.)
close this folder8. Writing and reviewing an EIA report
close this folder8.2 Review of an EIA report
View the document(introduction...)
View the document8.2.1 Purpose of the review
View the document8.2.2 Information and expertise needed for review
View the document8.2.3 Strategy of the review
Open this folder and view contents8.2.4 Approach
View the document8.2.5 Specific document review criteria

(introduction...)

Review serves several purposes, each requiring somewhat different review skills. Technical accuracy and completeness are assumed by using independent experts who have no vested interest in promoting development or withholding project approval.

8.2.1 Purpose of the review

An EIA will usually contain a large amount of information about the form and consequences of a development. It is the purpose of a review to:

• provide the reviewers with a framework within which to interpret this information;

• enable reviewers to assess the quality and completeness of the information relatively quickly;

• enable reviewers to make an overall judgement of the acceptability of the EIA as a planning document.

Table 8.1 Suggested/required components of an EIA report

Contents

Aid agency


World Bank

EBRD

IDB

AsDB

AfDB

Executive summary

Yes

Yes

Yes by project team

Yes

Yes

Policy, legal, institutional framework

Yes

Yes

Yes

Yes

Yes

Project description

Yes

Yes

Yes

Yes

Yes

Baseline data

Yes

Yes

Yes

Yes

Yes

Environmental impact analysis

Yes

Yes

Yes

Yes

Yes

Cost/benefit analysis

No

No

Yes (case-by-case)

Yes

No

Analysis of alternatives

Yes

Yes

Yes (when applicable)

Yes

Yes

Mitigation plan

Yes

Yes

Yes

Yes

Noa

Institution building

Yes

Yes

Yes

Yes

No

Environmental monitoring plan

Yes

Yes

Yes

Yes

Yes

Consultation

Yes

Yes

Yes

Yes

Yes

a But discussion of mitigative measures adopted in project plan. EBRD, European Bank for Reconstruction and Development; IDB. Interamerican Development Bank; AsDB, Asian Development Bank; AfDB, African Development Bank.

8.2.2 Information and expertise needed for review

Reviewing is normally done by planners and other interested parties who are familiar with the requirements of the regulations relating to environmental assessment and have at least a basic, non-specialist knowledge and understanding of impact assessment methodologies and current ideas on best practice in EIA.

8.2.3 Strategy of the review

Reviewers should not attempt to refute the findings presented in an EIA report or to supplant them with conclusions of their own. Reviewers should, rather, be alert to areas of weakness, omission, or even concealment in the report. These may most often occur when certain tasks are omitted, unsuitable or ad hoc methods are used, biased or inaccurate supporting data are introduced, often without references, or the rationale or justification for conclusions is not given.

It should be noted that, in order to promote objectivity in EIA report reviewing, it is recommended that each EIA report should initially be separately reviewed by two different reviewers who should then endeavour to reconcile any differences when finalizing their joint review.

The minimum information that an EIA report should contain, in any particular case, is usually specified in the regulations of the respective country. It is clearly an important consideration in deciding the suitability of the environmental impact statement as a planning document that these minimum data should be provided.

(introduction...)

Most of the few pieces of literature which have addressed the problem of reviewing and evaluating environmental impact statements have attempted to increase the evaluator's depth of understanding of the subject matter associated with the problem area. The evaluator, familiar with the document, then presumably is better prepared to examine the statement and either agree or disagree with its contents as developed by the author. This section presents various approaches to systematic EIA review and suggests other examples related to the review procedure classifications previously identified.

8.2.4.1 Independent analysis

In order to conduct an independent analysis, the reviewer theoretically should have complete familiarity and knowledge of the proposed projects and alternatives. Utilizing this information, a "mini-EIA'' could be developed and the resultant analysis compared with the document being reviewed. If a particular EIS methodology was utilized in the analysis, the reviewer could repeat the analysis, utilizing a different methodology, and compare results. Obviously, the majority of reviews and reviewers outside the proponent agency would not have this degree of familiarity with the project and its associated alternatives and impacts. At second best, the project purpose and discussion of alternatives and description of the affected environment must be sufficiently detailed in the EIA for the reviewer to evaluate the environmental consequences of the proposal.

During the independent analysis, the reviewer can utilize points which can be developed from the outline of the EIA report content described earlier. Other summaries can be developed utilizing general document review and technical review considerations. After the review has been completed, summaries may be reported. The responsible official and/or decision maker may then utilize these summaries in determining:

• changes or modifications needed in the EIA;
• decisions to release the document for public and inter-agency review;
• decisions to proceed with, modify, or halt the project and/or alternatives.

8.2.4.2 Predetermined evaluation criteria

Evaluation criteria for use by reviewers could take many forms. The form could range from a short, concise statement answering certain questions concerning the proposed activity, to a weighted checklist which portrays numerical values for different criteria which can be compared to index values. The contents of this analysis could be attached to the EIA and used in the decision-making process. Majority and minority opinion of the reviewers could also be included as another decision parameter to be considered by the responsible official.

A wide variation in mission and programmes is encountered between agencies and even within a single agency. This increases the difficulty in developing a single set of criteria that can be utilized to evaluate all federally related projects. The more specialized the agency activities, the more detailed the criteria that can be utilized, whereas the more variable the projects that can be encountered, the greater the generalization of the criteria. Generalized criteria, if properly selected, still have the capability of directing the statement review so that it is an effective tool for decision makers.

8.2.4.3 Ad hoc review

A third form of review will be discussed for those who may find themselves in the position of wanting to review an EIS but not wishing to employ the detailed, structured approaches suggested above. For those reviewers, the following sequence of activities is suggested.

1 Familiarize yourself with the prescribed outline and content of the respective agency implementing the EIA. This will provide you with an idea of the general sequences and format to be expected as you examine the body of the EIA.

2 Read the summary. This will provide an overview of the project, its alternatives, and the anticipated environmental consequences.

3 Examine the table of contents to determine the location of the various parts of the EIA. Depending on your familiarity with the project and/or the affected environment, you may wish to go directly to a specific section of the document.

4 Study the content of the EIA, looking for those items specifically identified in Table 8.2.

5 Focus on issues and concerns regarding administrative, general document, and technical review concerns previously identified.

6 Evaluate the EIA on the basis of your review.

Table 8.2 General document review criteria

Area of concern

Criteria

A Readability

• Write clearly
• Removal all ambiguities
• Avoid use of technical jargon; all technical terms should be clearly explained

B Consideration and focus

• Do not slant or misinterpret findings
• Avoid use of value-imparting adjectives or phrases
• Avoid confusion or mix-up among economic, environmental, and ecological impacts and productivity
• Avoid unsubstantiated generalities
• Avoid conflicting statements

C Presentation

• Use well-defined, acceptable qualitative terms
• Quantify factors, effects, uses, and activities that are readily amenable to quantification

D Data

• Identify all sources
• Use up-to-date data
• Use field data collection programmes as necessary
• Use technically approved data collection procedures
• Give reasons for use of unofficial data

E Methods and procedures

• Use quantitative estimation procedures, techniques, and models for arrival at the best estimates
• Identify and describe all procedures and models used
• Identify sources of all judgements
• Use procedures and models acceptable by professional standards

F Interpretation of findings

• Consider and discuss all impact areas before any are dismissed as not applicable
• Analyse controversial issues, and discuss the implications of all results
• Consider the implications for each area of a range of outcomes having significant uncertainty
• Analyse each alternative in detail and give reasons for not selecting it
• Scrutinize and justify all interpretations, procedures, and findings that must stand up under expert professional scrutiny

The kinds of questions that may be asked by decision makers while reviewing an EIA report are given below.

1 To what extent are both the beneficial and adverse environmental effects clearly explained?

2 How are the risks of adverse consequences evaluated and what are they?

3 What is the scope of the EIA in terms of external factors and time-lag effects?

4 What (if any) are the impacts on environmentally sensitive areas, endangered species and their habitats, and recreational/aesthetic areas?

5 What alternatives are considered: no project? other sites? other technologies?

6 What lessons from previous similar projects are incorporated?

7 How do the environmental effects change the costs and benefits of the project?

8 What adverse effects are unavoidable?

9 What public participation and review of project plans or the EIA have occurred?

10 What mitigation measures are proposed, and who is responsible for implementing them?

11 What are the parameters to be monitored so that the state of the environment can be studied throughout the project?

8.2.5 Specific document review criteria

This is a list of hierarchically arranged topics for reviewing the quality of environmental statements. There are four areas for review.

(a) Description of the development, the local environment, and the baseline conditions.

(b) Identification and evaluation of key impacts.

(c) Alternatives and mitigation of impacts.

(d) Communication of results.

(a) Description of the development, the local environment, and the baseline conditions

Description of the development.

• The purpose(s) and objectives of the development should be explained.

• The design and size of the development should be described. Diagrams, plans, or maps will usually be necessary for this purpose.

• There should be some indication of the physical presence and appearance of the completed development within the receiving environment.

• Where appropriate, the nature of the production intended to be employed in the completed development should be described, as well as the expected rate of production.

• The nature and quantities of raw materials needed during both the construction and operational phases should be described.

Site description.

• The land area taken up by the development site should be defined and its location clearly shown on a map.

• The uses to which this land will be put should be described and the different land use areas demarcated.

• The estimated duration of the construction phase, operational phase, and, where appropriate, decommissioning phase should be given.

• The numbers of workers and/or visitors entering the development site during both construction and operation should be estimated. Their access to the site and likely means of transport should be given.

• The means of transporting raw materials and products to and from the site, and the approximate quantities, should be described.

Wastes.

• The types and quantities of waste matter, energy, and other residual materials, and the rate at which these will be produced, should be estimated.

• The ways in which it is proposed to handle and/or treat these wastes and residuals should be indicated, together with the routes by which they will eventually be disposed of to the environment.

• The methods by which the quantities of residuals and wastes were obtained should be indicated. If there is uncertainty this should be acknowledged and ranges of confidence limits given where possible.

(Wastes include all residual process materials, effluents, and emissions. Waste energy, waste heat, noise etc., should also be considered.)

Environment description.

• The environment expected to be affected by the development should be indicated with the aid of a suitable map of the area.

• The affected environment should be defined broadly enough to include any potentially significant effects occurring away from the immediate construction site. These may be caused by, for example, the dispersion of pollutants, infrastructural requirements of the project, traffic, etc.

Baseline conditions.

• The important components of the affected environments should be identified and described. The methods and investigations undertaken for this purpose should be disclosed and should be appropriate to the size and complexity of the assessment task. Uncertainty should be indicated.

• Existing data sources should have been searched and, where relevant, utilized. These should include local authority records and studies carried out by, or on behalf of, conservation agencies and/or special interest groups.

• Local land use plans and policies should be consulted and other data collected as necessary to assist in the determination of the "baseline'' conditions, that is, the probable future state of the environment, in the absence of the project, taking into account natural fluctuations and human activities (often called the "do nothing'' scenario).

(b) Identification and evaluation of key impacts

Definition of impacts.

• A description should be given of the direct effects and any indirect, secondary, cumulative, short-, medium-, and long-term, permanent and temporary, positive and negative effects of the project.

• The above types of effect should be investigated and described with particular regard to identifying effects on or affecting humans, flora and fauna, soil, water, air, climate, landscape, material assets, cultural heritage (including architectural and archaeological heritage), and the interactions between these.

• Consideration should not be limited to events which will occur under design operating conditions. Where appropriate, impacts which might arise from non-standard operating conditions, due to accidents, should also be described.

• The impacts should be determined as the deviation from baseline conditions, that is, the difference between the conditions which would obtain if the development were not to proceed and those predicted to prevail as a consequence of it.

Identification of impacts.

• Impacts should be identified using a systematic methodology such as project-specific checklists, matrices, panels of experts, consultations, etc. Supplementary methods (e.g., cause/effect of network analyses) may be needed to identify secondary impacts.

• A brief description of the impact identification methods should be given, as should the rationale for using them.

• Methods should be used which are capable of identifying all significant impacts.

Scoping.

• There should be a genuine attempt to contact the general public and special interest groups, clubs, societies, etc., to appraise them of the project and its implications.

• Arrangements should be made to collect the opinions and concerns of relevant public agencies, special interest groups, and the general public. Public meetings, seminars, discussions groups, etc., may be arranged to facilitate this.

• Key impacts should be identified and selected for more intense investigation. Impact areas not selected for thorough study should nevertheless be identified and the reasons they require less detailed investigation should be given.

Prediction of impact magnitude.

• The data used to estimate the magnitude of the main impacts should be sufficient for the task and should be clearly described or their sources be clearly identified. Any gaps in the required data should be indicated and the means used to deal with them in the assessment should be explained.

• The methods used to predict impact magnitude should be described and be appropriate to the size and importance of the projected impact.

• Where possible, predictions of impacts should be expressed in measurable quantities with ranges and/or confidence limits as appropriate. Qualitative descriptions, where these are used, should be as fully defined as possible (e.g., "insignificant means not perceptible from more than 100 m distance'').

Assessment of impact significance.

• The significance to the affected community and to society in general should be described and clearly distinguished from impact magnitude. Where mitigating measures are proposed, the significance of any impact remaining after mitigation should also be described.

• The significance of an impact should be assessed, taking into account appropriate national and international quality standards where available. Account should also be taken of the magnitude, location, and duration of the impact in conjunction with national and local societal values.

• The choice of standards, assumptions, and value systems used to assess significance should be justified and any contrary opinions should be summarized.

(c) Alternatives and mitigation of impacts

Alternatives.

• Alternative sites should have been considered where these are practicable and available to the developer. The main environmental advantages and disadvantages of these should be discussed and the reasons for the final choice given.

• Where available, alternative processes, designs, and operating conditions should have been considered at an early stage of project planning and the environmental implications of these investigated and reported where the proposed project is likely to have significantly adverse environmental impacts.

• If unexpectedly severe adverse impacts are identified during the course of the investigation, which are difficult to mitigate, alternatives rejected in the earlier planning phases should be re-appraised.

Scope of effectiveness of mitigation measures.

• The mitigation of all significant adverse impacts should be considered and, where practicable, specific mitigation measures should be put forward. Any residual or unmitigated impacts should be indicated and justification offered as to why these impacts should not be mitigated.

• Mitigation methods considered should include modification of the project, compensation, and the provision of alternative facilities as well as pollution control.

• It should be clear to what extent the mitigation methods will be effective when implemented. Where the effectiveness is uncertain or depends on assumptions about operating procedures, climatic conditions, etc., data should be introduced to justify the acceptance of these assumptions.

Commitment to mitigation.

• There should be a clear record of the commitment of the developer to the mitigation measures presented in the statement. Details of how the mitigation measures will be implemented and function over the time span for which they are necessary should also be given.

• Monitoring arrangements should be proposed to check the environmental impacts resulting from the implementation of the project and their conformity with the predictions within the statement. Provision should be made to adjust mitigating measures where unexpected adverse impacts occur. The scale of these monitoring arrangements should correspond to the likely scale and significance of deviations from expected impacts.

(d) Communication of results

Layout.

• The layout of the statement should enable the reader to find and assimilate data easily and quickly. External data sources should be acknowledged.

• There should be an introduction briefly describing the project, the aims of the environmental assessment, and how those aims are to be achieved.

• Information should be logically arranged in sections or chapters and the whereabouts of important data should be signalled in a table of contents or index.

• Unless the chapters themselves are very short, there should be chapter summaries outlining the main findings of each phase of the investigation.

• When data, conclusions, or quality standards from external sources are introduced, the original source should be acknowledged at that point in the text. A full reference should also be included either with the acknowledgement, at the bottom of the page, or in a list of references.

Presentation.

• Information should be presented so as to be comprehensible to the non-specialist. Tables, graphs, and other devices should be used as appropriate. Unnecessarily technical or obscure language should be avoided.

• Technical terms, acronyms, and initials should be defined, either when first introduced into the text or in a glossary. Important data should be presented and discussed in the main text

• The statement should be presented as an integrated whole. Summaries of data presented in separately bound appendices should be introduced in the main body of the text.

Emphasis.

• Prominence and emphasis should be given to potentially severe adverse impacts as well as to potentially substantial favourable environmental impacts. The statement should avoid disproportionate space to impacts which have been well investigated or are beneficial.

• The statement should be unbiased; it should not lobby for any particular point of view. Adverse impacts should not be disguised by euphemisms or platitudes.

Non-technical summary.

• There should be a non-technical summary of the main findings and conclusions of the study. Technical terms, lists of data, and detailed explanations of scientific reasoning should be avoided.

• The summary should cover all the main issues discussed in the statement and contain at least a brief description of the project and the environment, an account of the main mitigation measures to be undertaken by the developer, and a description of any significant residual impacts. A brief explanation of the methods by which these data were obtained, and an indication of the confidence which can be placed in them, should also be included.