IEMA's 2015 EIA and ESIA conference and masterclass

23rd November 2015


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  • Management ,
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  • Biodiversity

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Adam Newsome

The ever-increasing size of environmental statements is leaving some practitioners with doubts over the scoping process, reports Catherine Early

Speakers at IEMA's conference and masterclass on environmental impact assessment (EIA) and environmental and social impact (ESIA) in November suggested that the process may consider too many issues, resulting in statements packed with superfluous information.

Jon Allen, senior environmental consultant at conference sponsor Royal HaskoningDHV, outlined to the 150 delegates his own organisation's study that showed a steady increase in the size of statements associated with offshore wind farms. In 2005 the Greater Gabbard project was covered in 2,267 pages but seven years later the Dogger Bank Creyke Beck scheme took up 9,509.

Neil Kedar, head of consents at Transport for London, highlighted several projects with unwieldy statements, including the Thames Tideway Tunnel, at 25,600 pages, and the HS2 rail project, at 39,610. HS1, in contrast, was 900 pages, he pointed out.

Rufus Howard, director of renewables and marine development at Royal HaskoningDHV, said one of the key reasons behind the growing size of environmental statements was the differing views from the various parties and stakeholders involved in defining the word "significant". For example, a project that may cause more traffic in a particular place would be considered significant by the local community but not by the secretary of state, who would focus on national impacts.

The EIA Directive states assessments should identify "significant" environmental impacts. The aim of the EIA was to inform the decision maker of these, not to be a comprehensive assessment of all impacts, Howard said. "If it was supposed to cover everything it wouldn't use the word 'significant'," he said.

Pointing to specific examples of huge environmental statements, such as that for HS2, Howard asked: "Is that informing the decision maker? Or is that just confusing them by not identifying what is significant?"

A better system could be set up whereby existing developments are used to gain evidence of impacts. This would be used to inform the EIA process for future developments, Howard said (see panel, below).

Kedar said: "The environmental statement is just one of a suite of documents. Do we really need all of it? It shouldn't be a dumping ground for everything in the submission, for example the case for the project."

The ES for the Forewind offshore wind farm

Financial matters

Another theme emerging from the conference was the changing perspective of international banks in assessing environmental and social risks when deciding whether to finance development projects.

The World Bank is now updating its environmental and social policies that dictate its lending. Known as "safeguarding policies", the rules have been in place for 20 years. Since then, many issues have come to the fore that need to be included in the policies, said Agi Kiss, regional environmental and safeguards adviser at the World Bank. The most prominent of these is climate change, which, she said, "is arguably squeezing out some other issues". Rather than having a separate policy on climate change, the bank is proposing to address it partly at a national level and partly at a project level. It has established specialist panels on issues such as fossil fuels that will be called on to assess projects.

Biodiversity is also a hot topic for respondents to the World Bank's consultation. The mitigation hierarchy, which is a way of prioritising action to reduce environmental harm to wildlife and habitats, is accepted in theory but, Kiss said, problems are caused in its implementation. Biodiversity offsets, whereby ecological harm is mitigated through the developer paying to make improvements elsewhere, are particularly controversial, and the bank has proposed that they should be used only as a last resort.

"The concern in many quarters is that, by identifying offsets as an option, people will go straight for it rather than through the mitigation hierarchy," Kiss said. She added that the bank was coming under increasing pressure to consider social issues such as human rights when deciding which projects to finance. The bank is planning to embed human rights within existing environmental and social standards rather than have a separate policy. "There's lots of debate that we're weakening environmental standards, but we're not," she said. Overall, the changes would move assessments of projects from a very rules-based process to more of a judgment process.

Equator Principles

Claire Wallace-Jones, director of environmental and social risk management at Barclays Bank, told delegates about changes to the Equator Principles. These were established in 2003 as a framework to assess environmental and social risk in projects. Barclays was one of the four founding banks behind the principles and leads working groups on climate change and social risk.

At October's annual meeting of the financial institutions signed up to the principles, climate change and human rights were the two big topics of discussion, Wallace-Jones reported. "We are starting to consider more seriously changing weather patterns, key natural dependencies, energy legislation and supply chain," she told the IEMA conference. In terms of human rights, specific due diligence may be required "in limited high-risk circumstances", she added. An example of a high-risk circumstance would be resettlement of a large number of vulnerable people due to a development project.

Similarly, Robert Adamczyk, senior environmental adviser in the environment and sustainability department at the European Bank of Reconstruction and Development (EBRD), said the organisation was "going very much into environmental and social due diligence". Its environment and social policy was updated in 2014.

The EBRD is different from other international finance institutions in that it requires projects to meet EU standards such as those in the EIA Directive, use of best available techniques and European energy community standards. Adamczyk said the EBRD's 10 performance requirements were broadly equivalent to the Equator Principles.

Corruption is a challenge that the EBRD encounters in many countries, he said. This might manifest itself in the ease with which it is possible to buy a development permit. The bank cannot undermine an EIA that has already been done "in-country" because it is left in a difficult position legally and politically. However, it can undertake supplementary due diligence, he warned.

Three of the biggest issues the bank faces in assessing projects are:

  • late consideration of environmental and social impacts by the developer;
  • a disconnect between engineers, economists and environmental and social teams; and
  • lack of scientific information and data such as biodiversity baselines.

The missing link?

A better way to inform decisions on the impacts that need to be included in an environmental statement would be to review all statements for a particular development type and identify which ones consistently arise, said Rufus Howard, director of renewables and marine development at Royal HaskoningDHV. "For example, we always say that an offshore wind farm has no impact on air quality, but no-one's ever monitored that so there's no evidence to prove it. So lawyers see a risk and want it covered in the statement," he said.

Results from a sufficiently large number of schemes could be used to develop what Howard calls "industry evidence plans" to inform the scoping process for EIA for different types of development. "That way only significant issues are included, you get a proportionate assessment and the EIA has served its purpose," he said. Measures put in place to mitigate potential environmental impacts from a development should be monitored, and the results fed back into the industry evidence plan. "Therefore the missing link is completed via the evidence plan."


IEMA would also like to thank AECOM, Ramboll Environ, Mott macDonald, Peter Brett Associates, Waterman Group and WSP|Parsons Brinckerhoff for supporting the conference.

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