Linking impact assessment to an environment management system is vital, says Martin Broderick
Environmental impact assessment (EIA) is a well-established instrument. And, as with any deep-rooted tool, there is ongoing debate about how effective it really is. A key question that needs answering is whether an EIA, on its own, leads to a project – and the impacted environment – being managed in an acceptable way.
Appropriately employed, EIA is an important tool that helps to protect the environment, but it’s only one device in the policy toolbox. Other actions include monitoring and evaluation of the impacts of a project that has been the subject of an assessment (an “EIA follow-up”), together with subsequent management of the development’s performance through an environment management system (EMS).
By reducing negative impacts and highlighting positive outcomes, EIA follow-up can provide a safeguard for environmental protection. And the most effective EIA systems are those that use follow-up processes to tangibly link EIA and EMS.
Drivers of EIA development
The diffusion of EIA practice through legal instruments has been the primary driver for its take-up, although impetus has also come from the development of voluntary codes and principles in industrial and financial sectors. Additionally, EIA practitioners, through professional bodies such as IEMA, have produced a range of best-practice guidance.
Having emerged first as a systematic and integrated process in the US (through the 1970 National Environmental Policy Act), several other countries, including Australia and Canada, followed suit and adopted EIA. The EU EIA Directive (85/337/EEC) came into force in 1985 and applies to a wide range of defined public and private projects.
However, too often national EIA regimes, even those regarded as highly effective, only measure its success through procedural compliance rather than project outcomes. With EIA practice now well into its second generation it is vital that legislative regimes “mature” by embedding follow-up and monitoring.
Voluntary measures
Best practice indicates that projects be assessed to determine their social and environmental outcomes, and this activity is endorsed through several voluntary codes and industry-standard principles.
The World Bank, for example, first developed environmental guidelines back in 1988. The aim of its EIA operational directive is to ensure that projects proposed for funding by the bank are environmentally sound and sustainable.
The bank favours preventive measures over mitigatory or compensatory measures whenever feasible, and monitoring and follow-up are integral to procedure.
Another initiative comes from the International Finance Corporation (IFC), which promotes sustainable private sector investment in developing countries, and is part of the World Bank Group.
The IFC’s environmental and social safeguard policies and its disclosure policy mean the organisation applies sustainability standards to all investment projects to minimise their impact on the environment and on affected communities. Monitoring and follow-up are integral to the standards. In my own experience, the monitoring and follow-up requirements of the standards lead in a tangible way to better outcomes for all stakeholders.
The European Bank for Reconstruction and Development (EBRD) adopted its first environmental policy in 1991. It is accompanied by 10 related performance requirements based on good international sustainable development practice which EBRD-financed projects are expected to meet. The EBRD has defined specific performance requirements for key areas of environmental and social issues and impacts.
The Equator principles are a financial industry benchmark for determining, assessing and managing social and environmental risks in project financing. The principles are based on the World Bank and IFC guidelines and oblige financial institutions signing up to them to finance projects only where there is a guarantee that the social and ecological impact of projects are assessed.
There are 10 principles, and number four (entitled “Action plan and management system”) is the most relevant for linking EIA and EMS.
Principle four calls on developers to prepare a plan for implementing mitigation measures, corrective actions and effective monitoring in order to manage the impacts and risks identified in the impact assessment.
It also says they should maintain or establish an EMS that addresses the management of these impacts, risks and corrective actions to ensure they comply with applicable host country social and environmental laws and regulations.
In the UK, IEMA has also included follow-up as part of its best-practice guidelines. IEMA states that follow-up is one of the most important parts of the EIA process as it helps determine whether assessment makes a difference in terms of improved environmental protection.
Follow-up is essential for determining the outcomes of EIA. By incorporating feedback into the EIA process, post-development assessment enables organisations to learn from their experiences. It can and should occur in any EIA system to prevent impact assessment from simply becoming a pro-forma exercise.
Adding value
One of the characteristics of an advanced and effective EIA system is that it is linked to an EMS through follow-up. Appropriately employed, EIA is a key integrative element in environmental protection.
Monitoring and assessing post-development performance has the same goal as EIA, but its emphasis is placed on the action taken to achieve this goal. EIA has little value unless follow-up is carried out because without it the process will be incomplete and the consequences of EIA planning and decision making will remain unknown.
EIA follow-up can ensure the outcomes of the process are successfully incorporated into operational environment management systems, ensuring substantive and sustainable outcomes for projects.
