An EIA co-ordinator is not simply a project manager by another name, and is a specialist role in itself, argues Chris Prydderch at Amec Foster Wheeler.
The role of the EIA co-ordinator is often considered by developers to be no different to that of the project manager. It can be a hard sell to convince them that EIA projects will benefit in having both roles fulfilled, and indeed that they are often essential to the smooth-running of a successful project. The amended EIA directive provides a clear opportunity for the merits of such a role to be demonstrated.
Amec Foster Wheeler provides EIA services to a variety of clients across multiple sectors including renewables, property, infrastructure, waste and minerals. Projects within each of these sectors often have very different requirements, and potentially very different effects on the environment. Yet the role of an EIA co-ordinator is a constant and vital one. The cast of characters in a typical EIA project include:
- The developer; seeking to secure planning permission for their development, while meeting the requirements of the relevant consenting regimes, in the most cost-effective manner;
- The competent authority; who must determine whether the project should go ahead based on the information provided by the developer and taking account of advice from statutory and non-statutory consultees;
- Statutory and non-statutory consultees; who are under a duty to provide advice to the competent authority and are naturally protective of the resources which they are tasked with safeguarding and enhancing; and
- Other stakeholders such as landowners, local residents and employees.
To ensure a successful project an EIA co-ordinator must:
- Build relationships and carry out effective communication with their client, the developer, topic specialists, and stakeholders;
- Work pro-actively to ensure that all team members have a common understanding of the development proposal;
- Understand the consenting regimes under which the EIA is required, and consider the need for other environmental consents;
- Ensure that appropriate consultation is carried out throughout the EIA process;
- Drive the format and style of technical contributions to deliver consistency;
- Ensure that the need for the development, and alternatives to meeting this need, are considered;
- Lead the environmental design of the scheme by co-ordinating information about mitigation and enhancement opportunities, and regularly liaising with the developer and the project design team, and in some cases relevant stakeholders;
- Follow established good practice to environmental statement (ES) preparation; and
- Seek to ensure that the ES is technically robust.
Perhaps the most important task of an EIA co-ordinator is to ensure that the EIA remains impartial and is not influenced by the desire of the developer to gain planning permission. This can sometimes be a difficult concept for developers to grasp. Positive messages which seek to ‘sell’ the project, and which should be reserved for a planning statement, are often sought for inclusion in the ES as well. Amec Foster Wheeler is often responsible for the preparation of both planning and environmental statements, this distinction between the two documents, and their ultimate purpose, must always be maintained.
The newly amended EIA Directive (2014/52/EU) came into force on 15 May 2014. The new directive brings with it a number of changes for developers and their consultants to consider, including more stringent screening requirements, the introduction of new topics such as human health, climate change and resource efficiency, the mandatory monitoring of significant effects, and the requirement for developers to ensure that the EIA report is prepared by ‘competent experts’.
Where requested, there will be a requirement to base the EIA report on the scoping opinion. Opportunities for an integrated approach should also be considered where EIA is undertaken in tandem with other procedures such as Habitat Regulations appraisals or assessments required under the Water Framework Directive.
The directive therefore presents new challenges for developers who will face penalties for infringements which are “effective, proportionate and dissuasive”. A specialist EIA co-ordinator is ideally suited to ensure that these new requirements are met.
Could the project manager realise these varied project objectives? At Amec Foster Wheeler these roles are combined successfully where the project manager has experience in EIA. However, larger, more complex projects in particular benefit greatly from the appointment of a specialist EIA co-ordinator. In such cases, it is therefore ultimately in the developer’s interest to accept that an EIA co-ordinator is not simply a project manager by another name, and is a specialist role in itself.
Chris Prydderch is a principal consultant and EIA co-ordinator at Amec Foster Wheeler.