Adapting EIA for climate change
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Bryony Cunningham and Larraine Wilde on why impact assessments should do more to consider the effects of a changing climate
Mitigation interventions seek to reduce greenhouse-gas emissions, and national governments, development agencies and the private sector have invested considerable effort in recent years to prevent climate change.
By contrast, adaptation interventions are necessary responses to a changing climate, but, until recently, there has been little focus on adaptation. As a result, many large-scale, long-lived pieces of infrastructure and other developments continue to be designed with limited consideration of the potential effects of climate change on asset performance.
Ideally, climate change risks, and adaptation needs, should be incorporated into a project as early as possible, including in the environmental impact assessment (EIA) process, so the most cost-effective means for ensuring a development’s resilience to climate change is factored in before construction starts.
Routine approaches to undertaking EIA have been established using the assumption that the baseline climate is static. However, extreme changes in climate are likely to alter the relationship between a project and its local environment and communities throughout its lifetime.
The implications of climate change on developments that should be addressed in the EIA are fourfold:
- climate change may alter the effects of a project on the environment and society;
- climate change can modify the effects of the environment and social conditions on the project;
- local individual adaptation actions, including those of the project, may lead to unforeseen cumulative impacts; and
- monitoring and mitigation measures in EIAs may not be effective where projects have not been designed to cope with climate-related environmental and social changes.
For EIA practitioners there are inherent risks in undertaking impact assessments without considering climate change. Both the legal and insurance professions consider climate change to be “a reasonably foreseeable event”. As such, an environmental impact assessment that does not consider climate risks could be seen as incomplete and its author potentially negligent.
Individual chapters in some environmental statements have started to incorporate climate change considerations, such as adding 20% to peak flow calculations for flooding events (see panel below). The wider context of climate change, such as the availability of project resources, requires much greater consideration, however.
As IEMA has acknowledged, there is limited information on how climate change mitigation and adaptation should be taken into account in EIA practice. “This lack of advice poses a challenge for IEMA members, and wider EIA practitioners, wishing to deliver good-practice assessments,” the Institute states on its website.
Sensitivities and thresholds
Determining whether the project has climate-related sensitivities or critical climate-related performance thresholds is a rapidly evolving area. The UK Climate Projections provide projections for future changes to the climate based on simulations from climate models.
Organisations such as the Royal Commission on Environmental Pollution (RCEP) have also highlighted the critical nature of this issue. In its 2010 report Adapting institutions to climate change the RCEP concluded that the challenge of adapting to climate change was not appreciated sufficiently widely nor being addressed with anything like sufficient urgency.
At the start of the year, the government published the UK climate change risk assessment, which reviews the evidence of 700 potential climate change impacts. Also, IEMA has a dedicated web page on the issue, and, in 2010, produced a document outlining EIA and climate change principles. In addition, around 300 local authorities have signed up to the Nottingham Declaration on Climate Change, which recognises that climate change can have a real impact on how services are planned for and delivered.
In international terms, a number of countries – for example, Australia, Canada and the Netherlands – include a requirement to consider climate change impacts in EIAs. And in July 2010, the European Commission launched a public consultation for comments on how to update the EU EIA Directive, including how to encompass policy development on climate change.
The consultation followed the commission’s 2009 white paper Adapting to climate change: Towards a European framework for action. It stated that member states must develop guidelines to ensure that climate change impacts are taken into account in the implementation of the revised EIA Directive. However, the outcome of this process is still some way off.
Sources of climate change data and information outside of the UK can be sourced from the Intergovernmental Panel on Climate Change, Climate Wizard, UNFCCC and via national communications.
Some development banks, such as the European Bank for Reconstruction and Development and the Inter-American Development Bank, identify climate change risks as critical, and have devised risk profiling and screening tools to guide the process of risk identification and methods to address adaptation needs.
While a number of organisations and government bodies have made clear commitments to climate change adaptation in development, the practical application at project level, and in EIA, remains limited.
An area where further work could help to remedy this situation would be for governments to undertake strategic environment assessments in terms of particular sectors, technologies or geographical locations that are climatically sensitive to help highlight areas that could give cause for concern.
This would also help prepare a framework for those at a project level to place potential cumulative effects into context. Whatever actions are taken by governments, it is incumbent upon practitioners to address climate change risks in impact assessments and for climate change practitioners to be involved in EIA teams as a matter of routine.
Six steps to incorporate climate change into EIA
Climate change risks and adaptation needs can be addressed at several stages in the environmental impact assessment (EIA) process, from initial scoping through to mitigation planning and subsequent project monitoring. While climate change mitigation is comparatively well developed, adaptation urgently needs to be incorporated into project design.
Environmental consultancy SKM Enviros and climate change adaptation specialists Acclimatise have developed some basic guidelines to help incorporate climate adaptation in EIA as part of a project supporting the European Bank for Reconstruction and Development to incorporate climate change risk and adaptation into its project cycle.
Step 1 – Scoping and analysis of alternatives
Step 2 – Analysis of legal requirements
Robust EIAs need to demonstrate project compliance with legal requirements. Note that England’s 2011 EIA Regulations require forecasting methods associated with assessments to be described. It is also worth noting that some legislation, regulations and standards in certain jurisdictions may be regularly revised in the light of changing knowledge about climate change impacts.
Step 3 – Baseline conditions
Step 4 – Impact assessment
Step 5 – Avoidance, minimisation, mitigation and compensation measures, and assessment of residual impacts
Step 6 – Environment management and monitoring plans
Environment management and monitoring plans (EMMP) should include monitoring and management of any climate-related risks and adaptation measures. The EMMP should also include monitoring, where there may be uncertainty regarding risks, and adaptation needs to assist future decision-making. Updated EMMPs should include any emerging climate change risks.
Applying climate change analysis in EIA as outlined in these steps allows developers, regulators and other stakeholders to take appropriate decisions in relation to climate change risk and adaptation measures, and can contribute to the sustainability and effective performance of projects.
Liverpool Waters takes on climate change
The Liverpool Waters vision involves regenerating a 60-hectare historic dockland site to create a high-quality, mixed-use waterfront quarter in the city centre. It is located on the east of the River Mersey estuary and work on the site is due to start later in the year, with completion by the 2040s.
Peel Holdings’ 30-year development timeframe means that climate change adaptation was a key consideration in preparing the environmental impact assessment (EIA) for the site. A particular challenge was considering the impacts of sea-level rise over the duration of the development, and beyond.
Given the long lifetime and high cost of the built environment, it is imperative that plans and investment projects take into account the changing risks over the coming 100 years or more. Sea levels have been generally rising since the end of the last Ice Age, but in the UK the movement of the land complicates forecasting future sea levels. Basically, the South East of the UK is sinking faster, relative to mean sea level, than the North West.
There is now evidence to indicate that climate change is accelerating the rate of ice depletion in the Arctic and pushing up average global temperatures to such an extent that the long-term rate of rise in sea level around the UK is faster than previously anticipated.
To these figures it is necessary to add the effects of potentially increased storminess, which augments wave heights, and storm surge, where water is forced into estuaries and onto the coast by sustained strong winds, together with the effect of low atmospheric pressure. As a result, water levels can occur considerably above those which would be expected on account of astronomical tide levels alone. Clearly, the situation is highly complex.
The various climate change model scenarios set out in the UK Climate Projections 2009 (UKCOP09) take account of a range of political decisions and global economic growth over the next century. These will influence the likely human impact on average sea levels that will prevail in Liverpool in 100 years’ time, and the allowances that should be made for potentially higher waves and surge. What these show is that there is considerable uncertainty as to the predicted levels that can be most appropriately dealt with by a “managed adaptive approach” – that is, to invest now in actions that manage today’s risks, but keep options open so better decisions can be continually made over the whole life of investments.
This issue has been a particular concern for Liverpool Waters because of the need to preserve the heritage assets of the former docklands, part of which is a World Heritage site, and means that alteration of these highly significant features has to be avoided.
The overall approach to the Liverpool Waters development has been to retain the remaining historic dockland surface features that are of heritage significance. Historic buildings will be carefully conserved to incorporate resilience and land uses appropriate to the future flood-risk exposure.
For the proposed new buildings, minimum finished floor levels have been specified in the flood-risk assessment supporting the EIA. Also, there is a requirement that any residential occupation is at first-floor level or at such a level that future flood risk will not become a problem. Typically, levels are set to be above the 1-in-200-years flooding level, including an assessment of climate change increases in sea level, as recommended by Defra. These figures take account of the climate change scenarios modelled in UKCOP09.
The option to use property-level protection, such as flood barriers for doors, has not been discounted and remains part of the overall managed adaptive approach. Future access and egress arrangements during a flooding event are considered as part of this approach as it is essential that, in such circumstances, vehicular access can be maintained to properties. It has therefore been necessary to consider the creation of routes that do not conflict with the historic features requiring preservation.
The longevity of the development phase and subsequent occupation presents a real challenge to the redevelopment of many prime coastal waterfront locations in the UK. However, by adopting a managed adaptive approach, appropriate development specification can be provided to ensure ongoing flexibility, so future levels of protection will not be prejudiced, while at the same time it will preserve the important heritage assets.
Matthew Elliott, technical director at WYG
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