Role of Environmental Statement Review in EIA Process

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Environmental Impact Assessment as a tool for decision making has been formally initiated in late sixty’s at USA through National Environmental Protection Act, 1969 (Glasson et al., 2012, p.50) which has been now adopted by majority of countries of the world (Sadler, 1996, p.25; Petts, 2009; NCEA, 2013).
To monitor the quality of Environmental Statements (on which the overall success of the process depends most) review packages or criteria’s has been first developed in 1987 by Ross for Canadian ESs (Lee and Colley, 1992). Following several initiatives in this arena, Lee and Colley developed their review package in 1990, which has been amended at 1999 lastly (Lee et al., 1999), and it is being used widely for assessing ESs. European commission guideline on EIS review is another precise guideline to evaluate (EC, 2001). Both process has been criticized for the inadequacies to address all the issues (Põder and Lukki, 2011) and variability of scrutiny by reviewers depending on their personal skills and competencies (Peterson, 2010).

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Role of Environmental Statement Review in EIA Process

  1. 1. Title: The Role of ES Review Submission Date: November 9, 2013 University ID Number: 9297731 Word Count: 1548
  2. 2. 1. Introduction Environmental Impact Assessment as a tool for decision making has been formally initiated in late sixty‟s at USA through National Environmental Protection Act, 1969 (Glasson et al., 2012, p.50) which has been now adopted by majority of countries of the world (Sadler, 1996, p.25; Petts, 2009; NCEA, 2013). To monitor the quality of Environmental Statements (on which the overall success of the process depends most) review packages or criteria‟s has been first developed in 1987 by Ross for Canadian ESs (Lee and Colley, 1992). Following several initiatives in this arena, Lee and Colley developed their review package in 1990, which has been amended at 1999 lastly (Lee et al., 1999), and it is being used widely for assessing ESs. European commission guideline on EIS review is another precise guideline to evaluate (EC, 2001). Both process has been criticized for the inadequacies to address all the issues (Põder and Lukki, 2011) and variability of scrutiny by reviewers depending on their personal skills and competencies (Peterson, 2010). 2. Role of ES Review within EIA Process  Evaluate the approach and findings of the study, in relation to the actual effects of the development, the accuracy of the prediction made and the effectiveness of mitigation measures proposed (Harrop and Nixon, 1998, p.129).  Assess whether findings and results are presented in an understandable manner and provides information that is sufficient and relevant for decision making (Wood, 2003; Sadler, 1996).
  3. 3.  Check whether the ES fulfills the detail requirement of EIA (impact prediction and significance, alternatives consideration and mitigation measures) in other word quality assurance of EIA process as a whole (Fuller, 2009).  Validate the underneath science and methodology (Glasson et al., 2012, p.176).  Measure harmony with the specified ToR or Scoping guidelines (Sadler, 1996, p.122).  Play a vital role in ensuring the effectiveness of EIA (Lee and Colley, 1992; Lee et al., 1999).  Helps decision maker or respective authority to take decision – whether to ask for further information / refusal (Sadler, 1996, p.122).  Examine whether ES includes the views of all parties and represents them fairly (Sadler, 1996, p.131) 3. Review of Three (3) ES from Bangladesh: Evaluation Criteria – ‘Impact Significance’ 3.1 Justification Bangladesh is a country with a transitional economy (low income to middle income), having on an average 6% economic growth in the last decade (WB, 2013). Since early 90‟s there has been an increasing trend of Foreign Direct Investment (BOI, GoB, 2012), which comes with the investment in industrial and infrastructure sector. Consequently this type of interventions causing Environmental and Social impact, which as a result brought EIA to measure the degree of intrusion, by the donors first in the early 80‟s (Kabir 2012, p.40). Recent trend of investment is in energy sector because of the country‟s new exploration of gas and oil reserve and increasing high energy demand. Considering the above mentioned conditions, three (3) Environmental Statements (ES) from power sector has been selected for the analysis in this essay
  4. 4. i. Environmental Impact Assessment of 2x (500-660) MW Coal Based Thermal Power Plant to be Constructed at the Location of Khulna (BPDB, GoB and CEGIS 2013). ii. Environmental Impact Assessment of 108 MW Natural Gas Fired Power Plant at Ghorashal, Palash, Narshingdi (AECL et al. 2012). iii. Environmental Impact Assessment study of “Siddhirganj Maniknagar 11Km 230KV Transmission Line Project (SMTL)” (PGCB, GoB and CEGIS 2012). The aim of this part of the essay is to evaluate the Identification and Evaluation of Key Impact of those three (3) ES. Justification for selecting this criteria is backed by research findings of poor impact prediction and evaluation process of Bangladesh‟s EISs like other developing countries (Kabir, 2012; Ahammed and Harvey, 2004). Additionally, excellence of „impact significance‟ of an EIA is largely dependent on proper scoping, identification and determining magnitude. That‟s why the total Impact Identification and Evaluation process has been analyzed here. Review package of Lee and Colley (1999) will be used during the investigation but a country specific adopted version (Kabir and Momtaz, 2012, p.99) to address the legislative requirement has been used to make the analysis more appropriate (Lee et al., 1999, p.31).
  5. 5. 3.2 Assessment of Impact Identification and Evaluation of Three ES from Bangladesh Table-1: Result of Assessment Project-X (Coal Based Power Plant-Rampal) Project-Y (Gas Based Power Plant-Narsingdi) 2. Identification and Evaluation of Key Impacts B C Project-Z (11 Km Electricity Transmission LineSiddhirganj) D 2.1 Definition of Impacts A C C 2.1.1 Impact Types A C C 2.1.2 Impacts with Regard to Humans, Ecology etc. A C B 2.1.3 Impacts of Accidents B D E 2.1.4 Impacts as the Deviation of Baseline A B C 2.2 Identification of Impact B D D 2.2.1 Methods Used for Impacts B B C 2.2.2 Justification of Methods Used B F E 2.3 Scoping B C C 2.3.1 Arrangements for Scoping B C C 2.3.2 Methods of Collection of Opinions B C C 2.3.3 Selection of Key Impacts A B D 2.4 Prediction of Impact Magnitude B C E 2.4.1 Data Gaps B B C 2.4.2 Methods Used with Justification B D E 2.4.3 Quantitative Expression where Possible C E F *2.4.4 Uncertainty C F F 2.5 Assessment of Impact Significance A C E 2.5.1 Significance of Impact on Community and A C D 2.5.2 Methods Used for Evaluation of Impacts A B E 2.5.3 Justification of Methods Used B C F *2.6 Community Involvement B C D 2.6.1 Description of Community Affected A C C 2.6.2 Involvement of Community B C C 2.6.3 Methods of Community Involvement B D D 2.6.4 Inputs from Community C D E Project Criteria Environment *Country Specific Criteria (Adopted from Kabir and Momtaz, 2012 and Lee et al,. 1999)
  6. 6. Table-2: Assessment Symbols Symbol Explanation A Relevant tasks well performed, no important tasks left incomplete B Generally satisfactory and complete, only minor omissions and inadequacies C Can be considered just satisfactory despite omissions and/or inadequacies D Parts are well attempted but must, as a whole, be considered just unsatisfactory because of omissions or inadequacies E Not satisfactory, significant omissions or inadequacies F Very unsatisfactory, important task(s) poorly done or not attempted NA Not applicable. The Review Topic is not applicable or it is irrelevant in the context of this Statement Adopted and Reproduced from Lee et al. 1999 From the above assessment (Table-1 and Table-2) it can be summarized that those three ES is particularly weak in impact identification, prediction of magnitude and assessment of significance which supports the claim made by few earlier research (Momtaz, 2002, p.175; Ahammed and Harvey, 2004, p.73; Kabir et al., 2010, p.4; Kabir, 2012, pp.136–146, 233; Kabir and Momtaz, 2012, p.96) on Bangladesh EIA process. Definition, scoping and community involvement is within the acceptable limit. Identification procedure is mainly weakened by the justification of the method used, which seemed to be a common flaw in all. Magnitude prediction is defected by justification of method used specific to project and scale, quantitative expression of magnitude other than just blurred classification (i.e. major, minor etc.) and absence of confidence level or certainty of the predicted value (project-Y & Z). Significance of impact is faded by type and justification of method used for the evaluation (project-Y&Z).
  7. 7. 3.3 Assessment within the Context of Bangladesh EIA Regulation EIA in Bangladesh has been incorporated formally within legislation through Environment Conservation Act, 1995 (MoEF, GoB 1995) and detailed specification has been provided later via Environment Conservation Rules, 1997 (MoEF, GoB 1997a) and EIA Guidelines for Industries (MoEF, GoB 1997b). Basic requirements in case of impact assessment within the EIA process are (according to MoEF, GoB 1997b) –  Process – impact identification, prediction and significance  Compare with the „Future-Without-Project‟ (FWP) scenario  Impact of all alternatives under consideration  Impact according to different project stages (pre-construction, construction, operation & decommissioning)  Impact with and without mitigation measures  Impact evaluation and significance according to - type, extend, spatial and temporal nature, likelihood, and reversibility.  Cumulative Impact Assessment  Summary presentation in a convenient way (i.e. matrix) Project-X: Addressed the process as a whole satisfactorily. Impact identification in various stages (i.e. impact form coal transportation), evaluation, significance and presentation with respect to mitigation measures (BPDB, GoB and CEGIS 2013, pp.299–334) is excellent. But absence of proper impact analysis for alternatives and cumulative impact assessment made it biased.
  8. 8. Project-Y: Scoping, evaluation, scenario with and without mitigation and presentation is satisfactory through following a simple matrix (AECL et al. 2012, p.102). But absence of justification of model used (i. e. SCREEN), considering national standard too stringent for SOx, under estimating cumulative impact along with ambient industries, absence of justification for the stack height made this statement faulty. Project-Z: Impact of alternative routes, different project stages and with and without mitigation scenario is well documented (PGCB, GoB and CEGIS 2012, pp.23–30, 65–71). But complete absence of impact significance and scientific data for impact prediction made this ES faulty and unacceptable. 4. Conclusion The above two analysis (according to Lee and Colley review package and within the context of Bangladesh EIA legislation) give us the anonymous result that Project-X and Project-Y fulfills the minimum requirement, in case of impact identification and significance. On the other hand Project-Z fails to address all the issues required within the extent of Bangladesh EIA regulation.
  9. 9. References: AECL, REPL and IDCOL. (2012). Environmental Impact Assessment of 108 MW Natural Gas Fired Power Plant at Ghorashal, Palash, Narshingdi. Dhaka: Adroit Environment Consultants Ltd., Regent Energy and Power Ltd. & Infrastructure Development Company Limited. [online]. Available from: http://www.idcol.org/Download/EIA_REPL.pdf [Accessed: October 20, 2013]. Ahammed, R. and Harvey, N. (2004). Evaluation of Environmental Impact Assessment Procedures and Practice in Bangladesh. Impact Assessment and Project Appraisal, 22(1), pp.63–78. [online]. Available from: http://www.tandfonline.com/doi/abs/10.3152/147154604781766102 [Accessed October 15, 2013]. BOI, GoB. (2012). Inflows of Foreign Direct Investment. Board of Investment Bangladesh. [online]. Available from: http://www.boi.gov.bd/index.php/investment-climate-info/fdi-in-bangladesh [Accessed: November 7, 2013]. BPDB, GoB and CEGIS. (2013). Environmental Impact Assessment of 2x (500-660) MW Coal Based Thermal Power Plant to be Constructed at the Location of Khulna. Dhaka: Bangladesh Power Development Board, Power Division, Ministry of Power, Energy and Mineral Resources, Government of the People‟s Republic of Bangladesh & Center for Environmental and Geographic Information Services. [online]. Available from: http://www.bpdb.gov.bd/download/coal_EIA_report_rampal_khulna/EIA%20of%202x%20%28500660%29%20MW%20Coal%20Based%20Thermal%20Power%20Plant%20at%20Rampal%20in%20Bagerhat% 20District,%20Khulna.pdf [Accessed: October 20, 2013]. EC. (2001). Guidance on EIA - EIS Review. Luxembourg: European Commission. [online]. Available from: http://ec.europa.eu/environment/eia/eia-guidelines/g-review-full-text.pdf [Accessed: October 25, 2013]. Fuller, K. (2009). Quality and Quality Control in Environmental Impact Assessment. In J. Petts, ed. Handbook of Environmental Impact Assessment: Volume 2: Impact and Limitations. John Wiley & Sons, pp. 55–78. Glasson, J., Therivel, R. and Chadwick, A. (2012). Introduction to Environmental Impact Assessment. 4th ed. Routledge. Harrop, D.O. and Nixon, J.A. (1998). Quality Assurance in EA - ES Review and Post Project Analysis. In Environmental Assessment in Practice. Routledge Environmental Management. Routledge. Kabir, S.M.Z. (2012). A Critical Evaluation of the Environmental Impact Assessment System in Bangladesh Using a Holistic Approach. PhD. Dissertation. Australia: University of Newcastle. Faculty of Science and Information Technology , School of Environmental and Life Sciences. [online]. Available from: http://nova.newcastle.edu.au/vital/access/manager/Repository/uon:11245 [Accessed: November 7, 2013].
  10. 10. Kabir, S.M.Z. and Momtaz, S. (2012). The Quality of Environmental Impact Statements and Environmental Impact Assessment practice in Bangladesh. Impact Assessment and Project Appraisal, 30(2), pp.94–99. [online]. Available from: http://www.tandfonline.com/doi/abs/10.1080/14615517.2012.672671 [Accessed: November 7, 2013]. Kabir, S.Z., Salim Momtaz, A. and Gladstone, W. (2010). The Quality of Environmental Impact Statement (EIS) in Bangladesh. In IAIA10 Conference Proceedings. The Role of Impact Assessment in Transitioning to the Green Economy, 30th Annual Meeting of the International Association for Impact Assessment. Geneva: IAIA, pp. 1–5. [online]. Available from: http://www.iaia.org/iaia10/documents/pdfs/The%20Quality%20of%20Environmental%20Impact%20Statement %20(EIS)%20in%20Bangladesh.pdf [Accessed: October 15, 2013]. Lee, N. et al. (1999). Reviewing the Quality of Environmental Statements and Environmental Appraisal. Manchester: EIA Center, Department of Planning and Landscape, University of Manchester. [online]. Available from: http://www.sed.man.ac.uk/planning/research/publications/wp/eia/documents/OP55.pdf [Accessed: October 24, 2013]. Lee, N. and Colley, R. (1992). Reviewing the Quality of Environmental Statements. Manchester: EIA Center, Department of Planning and Landscape, University of Manchester. [online]. Available from: http://www.sed.manchester.ac.uk/planning/research/publications/wp/eia/documents/OP24PARTA.pdf [Accessed: October 24, 2013]. MoEF, GoB. (1995). Bangladesh Environment Conservation Act, 1995. [online]. Available from: http://www.moef.gov.bd/html/laws/env_law/153-166.pdf [Accessed: October 25, 2013]. MoEF, GoB. (1997a). Bangladesh Environment Conservation Rules, 1997. [online]. Available from: http://www.moef.gov.bd/html/laws/env_law/178-189.pdf [Accessed: October 25, 2013]. MoEF, GoB. (1997b). EIA Guideleines for Industries, 1997. [online]. Available from: http://www.doebd.org/6_EIA_Guidelines_for_Industries.pdf [Accessed: October 25, 2013]. Momtaz, S. (2002). Environmental Impact Assessment in Bangladesh: a Critical Review. Environmental Impact Assessment Review, 22(2), pp.163–179. [online]. Available from: http://www.sciencedirect.com/science/article/pii/S0195925501001068 [Accessed: October 15, 2013]. NCEA. (2013). Environmental Assessment: World map of EIA/SEA legislation. Netherlands Commission for Environmental Assessment. [online]. Available from: http://www.eia.nl/en/environmental-assessment [Accessed: May 11, 2013]. Peterson, K. (2010). Quality of Environmental Impact Statements and Variability of Scrutiny by Reviewers.
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