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Saturday, August 12, 2017

How to improve Environmental Impact Assessment (EIA) Effectiveness

John Kakonge                                                                                                                                                            
In this piece John Kakonge unpicks the necessary but unforced task of carrying out Environmental Impact Assessments for development programming.
Environmental impact assessment (EIA) is now a global tool for ensuring that environmental concerns are integrated into the development project or programme planning process. In Africa, for example, it had started to be widely used after African ministers of environment endorsed its operability at the ministerial conference (AMCEN) in 1995. The effectiveness of EIA has been mixed and, in some cases, has fallen below expectations. There are many reasons for this. Given that a great deal has already been written on this subject, this article will focus on only a few of the related concerns, namely, corruption and management, the quality of the EIA, follow-up mechanisms, capacity-building and communication of EIA results.

Corruption and mismanagement
One of the challenges in explaining why EIA has not been effective involves civil and corporate corruption, , and mismanagement of the EIA process. For example, Shepherd (2012) notes that in Thailand, the EIA practise is frequently seen as illegitimate and fraudulent and the resultant recommendations are often overlooked unless complaints are taken up in the form of legal challenges. Shepherd adds that many developers negotiate in an opaque manner, that is behind closed doors, and local residents are rarely consulted. Similarly, Ridl (2012) acknowledges that KwaZulu-Natal Wildlife, a conservation agency in South Africa that was formerly an organization with international standing and prestige, is now corrupt and its officials are arrogant and at times openly obstruct the EIA process by refusing to adhere to the statuary time frames for responses. In addition, in Nigeria, Yusuf (2008) indicates his disappointment that the EIA practice has become a showcase for corruption and infraction of the EIA Act of Nigeria. This is due to the regulatory authority, which is the Ministry of Environment, Housing and Urban Development, being not fully transparent in terms of providing relevant information and data. According to Yusuf, the Ministry exercises power arbitrarily and unlawfully, resulting in corruption and blithe disregard for EIA regulations. As explained by King (2009), many EIAs have come to be mismanaged and corrupt and are often used to “lull government agencies and the public alike into thinking all’s well with a proposed project, while serious environmental impacts are swept under the rug”. Conversely, King (2009) argues that, in the United States, the consulting firms that prepare EIAs and other related work often end up forming part of their clients’ planning teams and their clients are almost invariably the proponents of the very projects that they are analysing. Accordingly, their analyses and results often end up being influenced by this relationship. This is most unfortunate, as it makes a mockery of the whole exercise and represents a breach of contract.
Generally, developing countries are particularly prone to mismanagement and environmental impact often has a low priority in their national policy and the required skills are not readily available. As stipulated by Winbourne (2002), leaders from developing countries “would rather sacrifice clean air and water, bio-diversity and forests if they can turn them into profitable businesses and support short-term political agendas and medium-term economic benefits”. Such actions, however, are especially detrimental, in that they perpetuate the mismanagement of the EIA process while leaving the country vulnerable to corruption and unexpected environmental consequences in the future.
Instead, EIAs should be properly managed to ensure the health and future sustainability of the environment and its resources. As demonstrated by Abaza (2004), environmental impact management is not implemented solely for future reward; it can also cut current costs dramatically and improve stakeholder relations. Accordingly, if managed appropriately, EIAs can provide for a healthier environment and sustainable economic growth, benefiting both present and future generations.
Quality of EIA reports
A second reason for the continued ineffectiveness of the EIA process can be attributed to the low quality and inconsistency of the EIA reports. From the available information, it can be seen that the quality of EIA reports vary widely from project to project. According to UN/ECA et al. (2007), some EIA reports are of very low quality and may also be excessively long and hard to understand regardless of the reader’s level of education or expertise. For instance, the EIA for the Tana Delta Integrated Sugar Project in Kenya is 412 pages long and couched in turgid technical and scientific language, with extensive chemical equations, complex economic graphs and Latin binomial species nomenclature (Mumias, 2007). This kind of report is way beyond the comprehension of many local officials and leaders.
In addition, independent comments received from the Kenya Wetland Forum in 2008 noted that the Tana Delta EIA study had huge gaps in vital information relating to hydrology and biodiversity, thus calling into question the report’s scientific soundness and accuracy. Another example may be seen in India, in the 1996 EIA for the Allain Duhangan project which was limited to a technical assessment of geological and engineering components, with little discussion of impact, in addition to a number of other flaws (Martin, 2007). Interestingly, even with these limitations, the Government of India gave its approval for the project to go ahead. As revealed by Lawrence (2003), many EIA reports fail to provide explicit and comprehensive solutions to negative envrionmental effects. In addition, lack of transparency on how to mitigate and monitor the environmental impact of projects has resulted in widespread frustration, thus also causing “inconsistencies in EIA quality and an EIA process that can be difficult to understand or reproduce.”
There are many reasons behind the poor quality of EIA reports, but one major cause stems from the simple fact that too many EIA reports are prepared with limited environmental information and data. As noted by the World Bank (2012), “the need for vast numbers of EIAs coupled with an absence of baseline environmental data resulted in mass production of EIAs of poor quality and little value.” In this context, we can refer to the recent South African conference on the topic “Ten Years of EIA in South Africa”, which was specifically designed to review the effectiveness of EIAs and whether or not they are worth the investment (Komen, 2011). Although the conference recognized the inadequacies of many EIAs (e.g., lack of environmental resources and government support), it concluded that EIAs are marginally effective and still a worthy investment. The World Bank (2012) also revealed that poor EIA reports are the products of poorly trained EIA practitioners. Too many EIAs are being conducted by practitioners with limited capacity and environmental information, resulting in poor-quality reports.
Nevertheless, the aforementioned examples seem to illustrate that there is no consensus regarding the quality of EIA reports. As O’Riordan and Turner (1983) point out, “it is not easy to produce good environmentally sensitive proposals which are satisfactory to all reasonably minded people, let alone to placate the objections of the less reasonably minded”. Regardless of the various viewpoints and acknowledging that no EIA report will ever be entirely infallible – there will always be an element of subjectivity in their preparation – there is still a need for more training packages for environmental practitioners, for not only to upgrade the quality of EIA reports but also to make the EIA process more effective.
Follow-up mechanism
To continue to have EIAs that are useful and strategically significant, there must be adequate follow-up mechanisms. Lack of these mechanisms is currently one of the weaknesses of the EIA process. Once an EIA has been prepared and approved by government authorities, it is supposed to include an environmental management plan for follow-up implementation. There are several reasons why EIA management plans are not subsequently implemented, including allocation of funds by the proponents, lack of enforcement staff from the government to make sure that this is done, lack of quality information and data, and lack of government commitment to carry out the follow-up activities, given other competing priorities.
Interestingly, Harmer (2005) notes that, even in the United Kingdom, the effectiveness of EIA follow-up needs to be revisited. According to Harmer’s study, the EIA consultants whom she interviewed, confirmed that there were sufficient controls elsewhere to ensure that follow-up was performed and there was therefore no need to spend time and more money on gathering new data. Thus, Harmer concludes that in order to lend credibility to the follow-up of the EIA system, the follow-up process should be made mandatory. In a similar vein, a workshop of African experts on the effectiveness of the EIA process, organized by the United Nations Economic Commission for Africa (UN/ECA) along with other organizations, also concluded that the responsibility should rest not only with the regulatory body but also with the private sector, working as a team ( UN/ECA et al., 2007).
As observed by Morrison-Saunders (2007), monitoring and evaluating the impacts of a project are “essential for determining the outcomes of EIA. By incorporating feedback into the EIA process, follow-up enables learning from experience to occur. It can and should occur in any EIA system to prevent EIA being just a pro forma exercise” (Morrison-Saunders, 2007). The report on the African Experts Workshop on Effectiveness of EIA
Systems 2007 also explains that “effective and efficient follow-up requires the capability to easily verify environmental management conditions” (UN/ECA et al., 2007). For this reason, an effective follow-up process requires a certain level of skill and capacity, which can really only be obtained through experience. Thus, follow-up not only boosts the effectiveness of current projects but also ensures the heightened effectiveness of future projects in that they have the added value of learning and skill development.
Many developing countries can draw on the services of professionals with knowledge of EIAs and other related areas. The challenge faced by these countries, however, is that, after completing college or university, some of these professionals gain no practical experience and are not involved in projects requiring the conduct of EIAs. According to the above-mentioned report on the African experts workshop on EIA effectiveness (UN/ECA et al., 2007), the capacity building problem cuts across the entire Africa region and, to address it, the experts recommend that EIA practitioners and experts should be accredited in consultation between the government and the private sector. The information provided by experienced and seasoned EIA experts should be referred by the government and regional bodies or organizations.
Moreover, in some cases, the national and regional EIA experts should team up with more experienced or seasoned experts from other regions in carrying out EIA reports. Case histories from Bangladesh and Guatemala show how many agencies have established registers of consultants, technical specialists and firms to carry out EIAs (World Bank, 2012). The World Bank (2012) adds that, in the above countries, the environmental agencies seek to issue certification or provide courses for EIA practitioners in order to improve the queality of EIAs. In fact, the Review of the Application of Environmental Assessments in Selected African Countries (2005) concluded, among other things, “Overcoming capacity constraints remains a major obstacle to the effective institutionalization and application of EIA in Africa”. The required capacity for the conduct of EIAs should include knowledge of procedures, analytical work, and technical and social skills. Consequently, the World Bank (2012) recognized that, “capacity building should be accompanied by practical experience development through integration and engagement of local expertise in undertaking EIA for large-scale development assistance projects”.
On the other hand, the capacity within the approving regulatory agencies in many of the developing countries is very important. A number of studies indicate, however, that many developing countries lack the capacity to review the EIA reports submitted to them and this in turn has resulted in a serious backlog. For example, in El Salvador, the World Bank (2012) noted that, in 2007, there was a backlog of 2,500 EIAs and this turned the EIA process into a bottleneck. Ideally, where the agencies do not have the capacity, funds should be made available to engage independent consultants to review these EIAs. In addition, the staff of these agencies should be upgraded to enable them to carry out their work faster and more effectively.
Communicating EIA results
In most African States, there are still challenges related to relaying EIA results to the stakeholders, communities and decision makers. Although the EIA reports are published for public inspection, this alone is not sufficient as a means of communicating the substance of the EIA and, as a consequence, the EIA loses its value and ends up being merely a fruitless legal requirement (Wood, 2003; Kakonge, 2006). There is no question that the communication of EIAs both horizontally and vertically plays a crucial role in reducing confusion, conflict and misconceptions about the project. This view is supported by Hughes (1999) who argues that communication of the EIA ensures that the EIA process addresses the main issues, harnesses local knowledge, improves the project’s capability to respond to the communities’ needs, reduces transaction costs (of conflict) and improves the acceptability of projects. The ineffective communication of EIAs in Africa can be primarily attributed to factors such as the complex and technical form in which the EIA reports are presented, language barriers, illiteracy, lack of availability of the reports for public review, and over-reliance on foreign experts in the EIA process (Wood, 2003, Kakonge, 2006). Admittedly, such reports and studies will never be mass circulated, or become best-sellers, yet attempts must be made to make them available to a wider audience.
One of the main impediments to the efficacy of EIAs in developing countries is the elaborate and technical manner in which the results are presented. For example, EIAs for complex technical or scientific projects such as infrastructure, industry (mining, oil and extraction) or hydropower production are presented in large volumes written in recondite scientific language. Unfortunately, this makes it difficult for both the local government authorities and the local communities to decipher them (Wood, 2003, Kakonge, 2006). A typical example is the 412-page EIA report on the Tana Delta Integrated Sugar Project described earlier (Mumias, 2007). The presentation of EIAs in such a technical form fails to communicate their message to readers who are not specialists and does not adhere to the United Nations Environment Programme principle of “providing (EIA) information in a form useful to decision makers” (UNEP, 1999).
Secondly, there are no formal requirements in most African countries for the systematic communication of EIAs to the stakeholders and the public (Wood, 2003; Omondi, 2008). Various strategies have been propounded in order to ensure effective communication in the EIA process. Wood (2003, p. 11) and Omondi (2008, p. 75) suggest the use of local experts to prepare EIA reports in Africa, as these experts would be able to engage in dialogue with local communities and leaders about the local impacts of the projects. This has clear advantages since local leaders and experts would have a better appreciation of the main issues and the reports would be more receptive to input from the communities. The EIA executive summary should also be provided to the media so that it can be published in the relevant local languages. The governmental environment agencies should also translate and post the relevant information by using printed media, newsletters, leaflets and/or booklets for the benefit of stakeholders and those members of the public (teachers, pastors, local counsellors, chiefs and others) who are literate. In order to reach the illiterate members of the community, however, it is important that other forms of mass media be used. These could include public debates, public enquiries, use of visual aids, billboards, television programmes, theatrical shows and radio broadcasts to reach as many people as possible (Robinson, 1996; Kakonge, 2006).
Clearly, the application of the EIA process and its practise vary from country to country and the process often serves solely to gain planning approval. Ironically, because of financial costs, there is no compliance at all with some of the EIA elements. For example, in Belize, there is no procedural provision to hold a public meeting, which limits the opportunity for the public to question or give comments on the project in question (World Bank, 2012). Public participation is, however, made possible through judicial review, but this does not lead to the revision of a decision. In the case of Jamaica, the National Resource Conservation Authority (NRCA) manages EIA procedures without formal requirements, meaning that NRCA has the discretion to decide whether an EIA is necessary or not (World Bank, 2012).
Moreover, the quality of EIA reports depends on whether the predictions contained in them can be monitored or audited. Regrettably, most of the available EIA reports are not easy to interpret and some suffer from information gaps. Although many training efforts have been made to upgrade the skills of EIA experts in developing countries, there has been little visible benefit obtained from this training, partly because of the heavy turnover of staff. Ways and means should be found to retain the available and experienced EIA experts. The regulatory ministry or agencies should provide incentive packages to EIA experts, including bonuses from planning permits and fines paid for those developments that do not meet the approval permit recommendations.
As mentioned earlier, developers or proponents are concerned more with the costs of EIA studies and the associated long delays before receiving approval from government authorities to proceed with the project. If the governments of developing countries are committed to the EIA process, they should build capacity in their regulatory agencies or ministries to ensure that the entire EIA is not only adhered to but it is also transparent, efficient and effective. In addition, once the results of EIA studies are available, the media should enter the process as a stakeholder and help to have the summaries of these studies translated into the necessary official and local languages and communicated to the public.
In short, EIAs are inevitably costly in terms of both money and time but, regardless of this, the process should be taken seriously and should not be compromised. At the same time, there is no pressure to carry out the EIA if it is not a legal requirement, including enforcement responsibility. Be that as it may, as recommended by the International Association for Impact Assessment/Institute of Environmental Assessment (IAIA/IEA 1999), there is a need to develop best-practice examples of EIAs, and the entire process should, among other things, be practical, cost effective, efficient, focused, participatory, interdisciplinary and transparent. Considerations well worth taking on board by both governments and practitioners alike.

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