Value of Environmental Impact Assessment

by Alan S. Cajes

Introduction

In my experience as manager of environment training courses, it is no longer surprising to meet a considerable number of people – project proponents, project managers, technical staff of government agencies, corporations and non-governmental organizations – who hold strong opinions against the practice of environmental impact assessment (EIA) in the country. Some of reasons, which surfaced in the course of my discussions with these people, on why the practice of EIA still needs a lot of improvements are:

Lack of appreciation about the nature and purpose of EIA. EIA is treated merely as a legal requirement that proponents must satisfy before pursuing a project or undertaking that falls under the environmental impact statement (EIS) system. It is not treated as an element of the project planning process, thus, it has no added value to project proponents.

Lack of capability on the part of government to implement the EIS system uniformly and well. As a result, there are environmentally critical projects that are operating either without an environment compliance certificate (ECC) or violating the ECC conditionalities.

Lack of capability to do EIA. In the case of the Philippines, the problem is not merely a technical one, i.e. relating to the appropriateness of methods and tools, credibility in the analysis of systemic impacts, and linking of stakeholders to the technical assessment process. It is also a problem of lack of appreciation and expertise in the areas of environmental conflict management and management of the public participation process.

These problems, for sure, cannot be addressed overnight. There have been various initiatives to address these problems but we are still in the journey of improving our performance in implementing the EIS system. We still need to be systematic in our decision-making processes, for instance, in order to sustain and institutionalize certain initiatives aimed to strengthen the EIS system. Another possible area for improvement is enhancement of government’s credibility to implement the EIS system. This is important because in the Filipino psyche, there is a direct correlation between the credibility of a system and the credibility of the institution that implements such system.

This paper is a contribution to current initiatives to improve the EIS system. Its central objective is to answer the question: What is EIA and why is it important? Much of the ideas contained in this paper are taken from personal experience in implementing environmental projects and training courses of the Development Academy of the Philippines, discussions with EIA experts, and from recent literature on EIA.

The Meaning of EIA

EIA may be defined as a process of identifying, predicting, evaluating and preventing, mitigating or enhancing the biological, physical, social and health impacts of a proposed project or undertaking before making major decisions and commitments for its implementation. As a process, it begins with the conception and ends with the termination of a project. As an activity, EIA involves multidisciplinary experts and stakeholders. In relation to environmental management, EIA is used, basically, as a planning tool but can also become a monitoring tool through the EIS and a regulatory tool through the ECC conditions.

A good EIA promotes good planning. Good planning implies good management. And good management is good business. The reasons why a good EIA promotes sound business practice are:

The assessment of the project and its alternatives through EIA leads to a more effective and efficient project. An effective project is one that attains the maximum benefits, while an efficient project is that which operates with the least cost.

The process saves time and money in the long run. By integrating environmental factors in decision-making at the planning stage, the proponent avoids expensive and sometimes controversial remedial action afterwards.

The process facilitates investment. Conducting an EIA and securing an ECC first before implementing the project are now required by financial and other institutions that loan money or make investment decisions for major development projects. The EIA can also help long-term investments by determining how resources can best be managed over the long term.

EIA keeps business, government and the community in touch. Inputs generated through public participation can improve community relations and ensure that funds are well invested. As a good management practice, EIA can support future prosperity. Through decisions based on recommendations from the process, there can be more prudent use of resources and a reduction of environmental threats to human health and ecosystems.

EIA leads to responsible decisions. Responsible decisions in turn are good for investment, good for the health of the proponent’s organization, its employees and the community where it operates.

Goals of EIA

EIA aims to facilitate sound and integrated decision-making by incorporating environmental considerations in the over-all project balance sheet. Before implementing a project or undertaking, the decision-makers must explore the widest possible environmental impacts of the proposed project and determine, through extended cost-benefit analysis, whether the project is viable or not. This is done through an analysis of the value of the positive and negative impacts, as well as the corresponding prevention, mitigation and enhancement measures.

A substantive objective of EIA is to achieve or support the goals of environmental protection and sustainable development. EIA, therefore, should be undertaken within the framework of generally accepted principles of environmental protection such as the following:

Ecocycle Society Principle

This principle seeks to prevent, as much as possible and practicable, the production of stock wastes that cannot be assimilated by the environment or those which goes beyond the limits of sustainability. It applies the principle of “cyclic materials management” in order to reduce and close the flows of materials to the extent that:

• The materials that society produce can be incorporated in the natural cycle without impairing the natural capacities and services;
• There is a reduction in the use and extraction of nonrenewable resources, and
• The natural capital meets fundamental human needs “without extraction exceeding growth in inflow.”

Critical Load

Critical load refers to the “highest load at which no harm is caused to the environment, even after long-term exposure.” This implies that any economic activity should ensure that its negative impacts to the environment remain at a level that is not significant. Thus, the carrying capacity of the environment is taken into due consideration in economic planning and project implementation.

Precautionary Principle

This principle is the philosophical expression of the self-preservation instinct. In practice, it means to “modify the manufacture, marketing or use of products or services to the conduct of activities, consistent with scientific and technical understanding to prevent serious or irreversible environmental degradation.” In essence, the principle means that prevention is always better than cure, thus, the exploitation of natural capital that causes significant damage to the ecological balance must be avoided. It can also be described as a principle that aims to achieve maximal reductions in pollution using the ‘best available technology.’

Substitution Principle

This principle states that substances and products that present a danger or threat to health and the environment are to be substituted by less or non-dangerous ones.

Best Available Technology (BAT) Principle

The BAT principle refers to the use of state of the art technologies that prevent or minimize the emission of pollution to the environment. The term “technology” includes the technology used, how it is designed, and its industrial feasibility, while the term “available” refers to existing technologies or procedures that can be applied at a reasonable cost.

Polluter Pays Principle (PPP)

The polluter pays principle, as the term implies, means that the polluter pays for the cost of pollution. The principle:

• Covers the cost of environmental protection;
• Covers pollution and control measures to promote the efficient use of limited material resources;
• Covers the cost of pollution control and cleanup, and compensation to victims or to those who suffer damage from pollution;
• Ensures the “effective distribution of the responsibility for cost and that it neither imposes demands nor excludes the possibility of reducing pollution to an optimum level,” and
• Includes the “internationalization of environmental costs and the use of economic instruments.”

Extended Product Responsibility (EPR) Principle

The extended product responsibility uses the life-cycle approach to identify strategic opportunities for pollution prevention and resource conservation. Based on this principle, the manufacturers, suppliers, users, and disposers of products have the collective responsibility for the “environmental effects of products and wastes streams.”

As an environmental management tool, EIA aims to lend support to efforts that promote the sustainable use and management of the natural resources. Specifically, EIA can help ensure that:

• The consumption of renewable resources does not exceed their capacity to regenerate;
• The consumption of renewable resources does not degrade the biodiversity of the ecosystem;
• The consumption of nonrenewable resources is minimal;
• A portion of the nonrenewable resources is set aside for the manufacture of renewable substitutes and the development of such substitutes is given priority in resource consumption;
• The consumption of nonrenewable resources is within minimum strategic levels;
• The assimilative and regenerative capacities of the environment are not degraded;
• The assimilative and regenerative capacities of the environment are not used for the dispersal of stock wastes or non-biodegradable substances;
• The natural life-support systems are not destabilized, and
• Environmental quality is not degraded.

Core Values, Guiding and Operating Principles of EIA

The practice of EIA in the Philippines and throughout the world has distilled some values, guiding and operating principles for the successful conduct of EIA. A study made by the United Nations Environment Programme (UNEP) identifies the following as the core values, guiding and operating principles of EIA, which can serve as a guide to reviewers of EIS:

Core Values

• Sustainability - the EIA process will result in international safeguards;
• Integrity - the EIA process will conform to agreed standards, and
• Utility - the EIA process will provide balanced and credible information for decision-making.

Guiding Principles

• Participation - appropriate and timely access to the process for all interested parties;
• Transparency - all assessment decisions, and their bases, should be open and accessible;
• Certainty - the process and timing of assessment should be agreed in advance and observed by all participants;
• Accountability - decision-makers are responsible to all parties for their actions and decisions under the assessment process;
• Credibility - assessments are undertaken with professionalism and objectivity;
• Cost-effectiveness - the assessment process and its outcomes will ensure environmental protection at the least cost to society;
• Flexibility - the assessment process should be able to adapt to deal efficiently and effectively with any proposal or decision-making situation, and
• Practicality - the information and outputs provided by the assessment process are readily usable in decision-making.

Operating Principles

EIA should be applied:

• To all development project activities likely to cause potentially significant adverse impacts or add to actual or potentially foreseeable cumulative effects;
• As a primary instrument for environmental management to ensure that impacts of development are minimized, avoided or rehabilitated;
• So that the scope of review is consistent with the nature of the project or activity and commensurate with the likely issues and impacts, and
• On the basis of well-defined roles, rules and responsibilities for key actors.

EIA should be undertaken:

• Throughout the project cycle, beginning as early as possible in the concept design phase;
• With clear reference to the requirements for project authorization and follow-up, including impact management;
• Consistent with the application of “best practicable” science and mitigation technology;
• In accordance with established procedures and project-specific terms of reference, including agreed timelines, and
• To provide meaningful public consultation with communities, groups and parties directly affected by, or with an interest in, the project and/or its environmental impacts.

EIA should address, whenever necessary or appropriate:

• All related and relevant factors, including social and health risks and impacts;
• Cumulative and long-term, large-scale effects;
• Design, location and technological alternatives to the proposal being assessed, and
• Sustainability considerations including resource productivity, assimilative capacity and biological diversity.

EIA should result in:

• Accurate and appropriate information as to the nature, likely magnitude and significance of potential effects, risks and consequences of a proposed undertaking and alternatives to it;
• The preparation of an EIS that presents information in a clear, understandable and relevant form for decision-making, including reference to qualifications and confidence limits in the predictions made, and
• Ongoing problem solving and conflict resolution to the extent possible during the application of the process.

EIA should provide basis for:

• Environmentally sound decision-making in which terms and conditions are clearly specified and enforced;
• The design, planning and construction of acceptable development projects that meet environmental standards and resource management objectives, and
• An appropriate follow-up process with requirements for monitoring, management, audit and evaluation that are based on the significance of potential effects, the uncertainty associated with prediction and mitigation, and the opportunity for making future improvements in project design or process application.

Conclusion

In closing, it should be borne in mind that the EIS system consists of three major components: Conduct of EIA, implementation of the environmental management plan (EMP), and compliance monitoring. These three activities have equal importance. Thus, there is a failure of the EIS system when there is a failure in any of the three activities. For what good is the EIS if it is not translated into actual practice through the EMP? And how would project managers know if they are implementing the EMP properly when there is no monitoring or measurement of compliance and performance?