Does Environmental Impact Assessment actually promote Sustainability?
By Oliver Sylvester Bradley
Introduction
Environmental Impact Assessments (EIA) is a process: identifying, predicting, evaluating and, ideally, monitoring potential impacts on the environment[1]. The Rio Declaration calls for EIA to be undertaken for activities that are likely to have a significant adverse impact on the environment[2] (It is a legal requirement in more than half the countries around the world[3]), the ultimate objective being the avoidance or reduction of such impacts and the promotion of sustainability[i][4]. EIA can be used to support claims of environmental merit[ii], inform decision makers, influence planning and encourage social learning, but is it actually succeeding in promoting sustainability?
Is EIA working?
Despite the vast number of alternative EIA methodologies available no satisfactory standard has yet been identified. Hertwich (1996) compared six of the most widely used[iii] environmental indices specifically developed for life cycle analysis (LCA) or design for the environment (DfE) and concludes that each of the methods has the potential to recommend an alternative that actually has a higher impact than other alternatives[5] and that ‘data requirements make them too complicated for sophisticated products and processes’.
Bruhn-Tysk’s (2001) review of 55 environmental impact statements (EISs) from Sweden concludes that in many cases, EIA does not serve as a tool for the goal of sustainable development[6]. Steinemann (2000) reports that none of the 42 EISs she studied contained adequate analysis of health impacts and more than half (26/42) did not mention health at all. The Green Building Handbook[7] admits that ‘often really crucial environmental factors are left out simply because they don’t fit into the methodology’[8], even the much celebrated BRE[iv] Green Guide to Specification[9] dedicates its first appendix to explaining that the information it contains ‘should in no way be seen as comprehensive’ although it is often touted as such.
Positive outcomes, in which environmentally sensitive alternatives are chose, will undoubtedly occur as a result of some EIAs but, in light of the above evidence, it seems that in general the process is far from fulfilling its aims.
So what’s going wrong?
There are numerous reasons why EIA fails in its aims; of these ‘motives’, ‘scope’ and ‘complexity’ are selected here for discussion.
The legal enforcement of EIA has made compliance a motive for assessment. This, coupled with prospects of creating ‘business advantages’ has bred a bastardised process which fails in its original aims. Steinemann (2000) explains that agencies are often primarily concerned with creating a ‘legally bullet-proof document’ (the EIS) and conducting extra research (e.g. considering human health effects) only casts a wider liability net. Complying with the law and ‘exploring environmental alternatives’ which genuinely promote sustainability, create entirely different results.
EIA is often regarded as a time consuming, financially burdensome hurdle to be passed, rather than an ongoing opportunity to explore alternatives and monitor progress. Defining the ‘scope’ is one of the initial steps of an EIA; this limits the size, scale and definition (hence time and cost) of impacts to be assessed but, changes in scale affect the results of EIAs and have important repercussions for the accuracy of the study. For example, a study by Joaõ (2001) into different scales of EIA for the Hastings Bypass found that the impact significance and the number of houses affected by air pollution from the road varied according to the scale used. This situation is made more serious when it is recognised that many environmental impact statements (EIS) fail to mention in explicit terms the scale used[10]. Considering that the proponents of an activity are at liberty to define the scope of their own EIA the process is fundamentally flawed in this respect.
EIAs attempt to predict the future, a particularly difficult task considering the compensatory and synergistic linkages present in the natural environment[11]. Jones (1985) considers ‘our hopes of accurately predicting all the impacts of an action that impinges upon the environment are virtually nil’[12]. We have no way of knowing how synthetic concoctions will react in the environment or whether predictions are entirely conclusive.
Taking health as an example, analysing a single outcome (e.g. cancer), due to a single toxin, over a single lifetime misses a range of other significant concerns such as endocrine disruption, neurotoxicity, chemical sensitivity, social impacts, intergenerational genetic damage and exposures to combinations of chemical, biological, or physical agents[13] - which are the most relevant impacts. Quantitative risk assessment is useless at determining causes and effects of exposures to multiple stressors and pollutants, over multiple time periods, which are precisely the types of exposures that confront humans.[14]
Assessors are therefore forced to make value judgments which ‘originate in a particular societal value system at a specific time in the frames of reference of culture and the goals of society and have nothing to do with expertise and science’[15] since they are based on opinion, rather than observation and experiment. Subjectivity and politicised evaluations are unavoidable, especially when assessors are employed by the proponents of an activity.
EIAs are also criticised for bad communication. Lengthy documents based on complicated data using complex terminology do not contribute to a ‘transparent process’, which is the main justification for providing ‘precisely wrong[v]’ results. Numerous other criticisms of EIA systems concern narrow boundaries (time and financial restrictions, limited alternatives), data gaps (insufficient, inaccurate and variable data) and simplified assumptions (eliminating variables that are viewed as less important) which all have seriously negative impacts on the validity of the process but are too detailed to discuss here.
But surely doing an EIA is better than not doing one at all?
Transparency is undoubtedly a good thing in such a subjective process, by allowing others to make their own interpretations of results. However, certain assumptions may be hidden by the methodology itself and regardless, justifying a system by calling it transparent demands that others have the time, skills and insight to come to their own conclusions which for the majority of laymen is simply not possible. Literal translations of subjective results are inevitable and encourage ‘perverse outcomes[vi]’ with potentially fatal results whilst the ‘global’ application of environmental scores (e.g. The ‘excellent’ BREEAM 98[vii] for Offices rating of Canary Wharf[viii]) undermines the entire EIA objective by ascribing fixed values to inherently variable situations, whilst promoting a ranking system which blatantly encourages literal translations.
Limiting alternative outcomes also makes EIA a unsatisfactory activity. It is not uncommon for a company to ‘dummy-up’ alternatives only so they can be torn down, and thereby add to the perceived attractiveness of the preordained alternative[16]. For the EIA process to work effectively it should involve alternative approaches not just alternative designs (e.g. Alternatives to company cars would be bicycles or tele-commuting rather than different types of cars) but often EIA occurs too late in the planning process for the consideration of such strategic alternatives.
So how can we make EIA better?
For EIA to promote sustainability it must be conducted with honest objectives. Whether this means changing UK guidelines or insisting on independent assessment the government should act swiftly if it does not want to lose this valuable tool; it should note that this has become a cynical, irrational and highly discretionary federal policy in Canada[17].
Public confidence in EIA is essential because without public input the system fails. A worrying survey in Essex found that 82% of the public believes that EIAs are biased towards the proponents[18]; this trend must be reversed for EIA to truly promote sustainability.
Public involvement can create a more widely accepted project, establish cooperative relationships and improve the implementation process[19]. This is the absolute crux of successful EIA; one which relies on the same community and national values which have demanded a response from complacent politicians and business organisations[20] over genetically modified food. A wider ‘thought-base’ provides more considered alternatives better suited at matching societal goals on both inter-generational and intra-generational levels.
To encourage successful participation IA professionals need to present data and information in a quickly understandable visual display. (see example in Fig.1) Only by providing a simple but accurate way to see trade-offs can we create a means to engage the interested parties in meaningful dialogue[21]; a requirement which none of the EIA methodologies provide. A ‘visual display’ of this kind may also help alleviate the problems associated with data gaps, assumptions and the overriding problems of subjectivity, by clearly representing the limits of knowledge and assumptions and encouraging debate. A ‘softer’, more qualitative display of information could also displace some of the inherent problems associated with quantifying the synergies of natural phenomena by representing problems as ‘shades’ rather than numbers.
The much ignored precautionary principle[ix] could also be reinforced by a visual EIA system as proponents of an action could be held responsible for demonstrating benignity of their actions if the ‘default’ position of an impact results sheet was always ‘unknown’, hence a bad result. (see Fig.2)
In order for EIA to provide significant benefits for sustainability there is also a severe need for the dissemination of information and education for both businesses and the public. Nick Raynsford, construction minister in the UK, boasts that “BREEAM has now established such a profile that you may well be a little suspicious if what was claimed to be an environmentally friendly building did not have a BREEAM assessment”[22]. However, a recent report[23] showed that, despite costing thousands of pounds and receiving an ‘excellent’ score the ‘BREEAM rating played no part in the potential tenants decision making process.’ In the executive summary for the building concerned, the ‘excellent’ rating is listed as 16th out of 17 of the building’s attributes, implying that BREEAM is of little help to marketing. Interestingly the developer had no desire to display the certificate in the foyer and said he would rather hang a ‘nice painting’.
Until the public understand the value of and demand more environmental alternatives EIA will play a limited role in promoting sustainability. It may also be used in a negative capacity by unscrupulous companies looking for methods (which can be written off against TAX) to provide ‘greenwash[x]’ and make claims of addressing sustainable development without actually implementing any environmental policies whatsoever.
Conclusions
EIA will always contain a level of uncertainty but can undoubtedly promote sustainability if used in the correct way. By involving independent assessors and stakeholders, using a more qualitative approach and communicating results diagrammatically EIA could embrace the subjectivity it creates and open it up for debate.
As a tool for providing exact detail regarding the impacts of alternatives EIA will continue to fail but nevertheless, its ability to facilitate rational social discourse about the effects, implications and sustainability of production and marketing systems[24] is of undeniable value.
By illustrating the transparency of EIA methodologies in a visual display, clearly understandable by chairmen, policy makers and the public alike it is possible for EIA to promote sustainable development, utilising participation as a tool to garner inter and intra-generationally informed decisions, and encourage social learning[xi].
[i] Sustainability: The outcome of sustainable development [3]
[ii]E.g. The Green Guide to Specification [6]
[iii] The six methods were: HHS: The health hazard scoring system, AHP: The analytical hierarchy process, MIPS: The material input per service unit, SEP: The Swiss eco-point, SPI: The sustainable process index, SETAC: The society of environmental toxicology and chemistry’s LCA method, and EPS: The environmental priority system.
[iv] Building Research Establishment, England
[v]EIA based on subjective assumptions and value judgments can never produce indisputable figures, implying any quantitative results will always be precisely wrong. Prompting the question: Is it better to be ‘generally correct’ or ‘precisely wrong’?
[vi] Uncertainty in the data, the model, or insufficient depth of analysis can lead to a better score for a sub-optimal alternative, an event that decision theory calls a ‘perverse outcome’. [5]
[vii]The Building Research Establishment’s Environmental Assessment Method for office buildings
[viii]Canary Wharf received an ‘excellent’ rating entirely because, at the time of the survey, it bought it’s electrical energy from a ‘green’ supplier, however it remains an extremely energy intensive structure which is in no way representative of an environmental solution.
[ix]The Precautionary Principle states that: Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. Rio Declaration 1992
[x]Greenwash: The falsification or deliberate misuse of environmental credentials.
[xi]Social learning: The process by which changes in the social condition occur – particularly changes in awareness and changes in how individuals see their private interests linked with the shared interests of their fellow citizens [24]
References
[1] Steinemann A. 2000 Rethinking Human Health Impact Assessment. Georgia Institute of Technology, Atlanta
[2] United Nations, 1992 The Rio Declaration UN
[3]Canter L. 1996 Environmental Impact Assessment. McGraw-Hill, New York.
[4] Karl-Henrik R. 2000 Tools and concepts for sustainable development, how do they relate to a general framework for sustainable development, and to each other? Journal of Cleaner Production 8. Elsevier.
[5] Hertwich E. 1996 Evaluating the environmental impact of products and production processes: a comparison of six methods. The science of the total environment. Berkley CA
[6] Bruhn-Tysk S. and Eklund M. (2001) Environmental impact assessment – a tool for sustainable development? A case study of biofuelled energy plants in Sweden.Environmental Impact Assessment Review 22 (2002) 129-144
[7]The Green Building Handbook CAT lecture notes Unit 7 2003
[8] Wozniak S. 1993 Environmental assessment of buildings and building developments – A logical methodology for the world. Mimeo. Bedmond Herts.
[9] Anderson J. and Shiers D. 2003 The Green Guide to Specification: an environmental profiling system for Building Materials and Components. Third Edition. BRE Blackwell Science.
[10] Joaõ E. 2001 How scale affects environmental impact assessment Environmental Impact Assessment Review 22 (2002) 289–310
[11] Wilkins H. 2003 The need for subjectivity in EIA: discourse as a tool for sustainable development. Environmental Impact Assessment Review. Ontario, Canada
[12] Jones M. Greig L. 1985 Adaptive Environmental Assessment Management: A new approach to environmental impact assessment. Methuen, Canada
[13] Steinemann A. 2000 Rethinking Human Health Impact Assessment. Georgia Institute of Technology, Atlanta.
[14] Steinemann A. 2000 Rethinking Human Health Impact Assessment. Georgia Institute of Technology, Atlanta.
[15] Beatie RB. 1995 Everything you already knew about EIA (but don’t often admit) EIA review
[16] Steinemann A. 2000 Improving Alternatives for Environmental Impact Assessment. Environmental Impact Assessment Review 21 (2001) 3-21.
[17] Nikiforuk A. 1997 The Nasty Game: The failure of environmental assessment in Canada. Sierra Club of Canada. accessed 11.5.2003
[18] Essex County Council 1995 Planning officers research P. 6; Construction Industry research and information association
[19] Shepherd A. and Bowler C. 1997 Beyond the requirements: Improving public participation in EIA. J Environ Plann Manage. 40(6):725-38
[20] Saunders T. 2002 The boiled frog syndrome: Your health and the built environment. John Wiley & Sons Ltd Chichester, UK
[21] Alton C. and Underwood P. 2002 Let us make impact assessment more accessible Environmental Impact Assessment Review 23 (2003) 141-153
[22]Raynsford N. 2003 Minister Unveils BREEAM '98 Master Builder on-line magazine. Federation of Master Builders. Accessed 13.5.2003
[23] Holmes J. and Hudson G. The Cutting Edge 2000 An evaluation of the objectives of the BREEAM scheme for offices: a local case study University of Northumbria at Newcastle ISBN 1-84219-031-8
[24] Riha S. et al. 1996 Environmental Impact Assessment: The Quest for a Holistic Picture. Pages 40-58 Proceedings of the Third IPM Symposium: Broadening Support for 21st Century IMP. USDA
25 Webler T. Kastenholz H. Renn O. 1995 Public participation in impact assessment: a social learning perspective. Environmental Impact Assessment Review 1995; 15(3):443-63