Environmental Impact

Assessment: Practical
Solutions to Recurrent
Problems, Part 1
These can be diffi- Both the EIA
cult times for envi- process and its out-
ronmental impact Coping with common process- comes are labeled as
assessment (EIA) unfair, unjust, and
practitioners! They related EIA difficulties inequitable. EIA
do their best to con- processes are de-
form to relevant leg- scribed as inflexi-
islation, regulations, ble, and EIA docu-
and guidelines; to ments are criticized
involve the community; to address the concerns for giving insufficient consideration to risks and
and preferences of proponents, review agencies, uncertainties.
and the community; and to reflect “good prac- Although these criticisms are not always ap-
tice” standards and legal precedents. Still, as Ex- propriate, they are far too common and too
hibit 1 illustrates, they often are assailed on often valid to be dismissed as the products of
multiple fronts by multiple stakeholders. unique local circumstances. EIA practitioners
Impact prediction and impact management need additional help to cope with these recur-
programs are said to be unscientific. Alternatives rent problems.
are viewed as too narrowly defined. Alternatives This need is addressed in considerable detail
evaluation and impact analyses are characterized in my book Environmental Impact Assessment—
as inconsistent, unsystematic, and nontraceable. Practical Solutions to Recurrent Problems, published
The EIA process and documents are faulted for by John Wiley & Sons (Lawrence, 2003). The
not adequately advancing environmental quality book provides detailed analyses of major recur-
and sustainability. EIA documents and processes rent problems that plague EIA practice. It also of-
are labeled as unfocused, too costly and time- fers practical solutions for application at both the
consuming, and of dubious quality and effective- regulatory and applied levels. This article offers
ness. The EIA process and related outcomes are prescriptive advice derived from the book.
described as reducing or inhibiting community
influence and control. Public involvement efforts
are depicted as tokenism and/or as manipulation. David P. Lawrence

© 2005 Wiley Periodicals, Inc.

Published online in Wiley InterScience (www.interscience.wiley.com).
DOI: 10.1002/tqem.20057 Environmental Quality Management / Summer 2005 / 39
 Exhibit 1. Demands on EIA Process Managers*

About This Article tical. Part II, which will appear in the next issue of
This article focuses on major prescriptive this journal, deals with how to make EIAs more
themes, concepts, distinctions, and advice for democratic, collaborative, ethical, and adaptive.
ameliorating recurrent, process-related problems
in EIA practice. General Approach of the Article
Because of the large number of specific prob- In this article, the general approach adopted
lems that need to be covered, this article has been for meeting the challenges associated with recur-
divided into two parts. Part I discusses how to make rent EIA problems encompasses the following
EIAs more rigorous, rational, substantive, and prac- components.

40 / Summer 2005 / Environmental Quality Management David P. Lawrence

Recurrent Problems Are the Point of • grounding the regulatory analysis by refer-
Departure ence to requirements and guidelines in four
Each problem is thoroughly explored. Proce- jurisdictions,
dures, frameworks, concepts, and methods appro- • evaluating each process with good practice
priate for ameliorating each problem are dis- standards, and
cussed. • using summaries and checklists to facilitate
process application.
Discussion Encompasses the Range of Issues
Facing EIA Practitioners Conventional EIA Processes
Each topic discussion begins by outlining the
problem and the direction that needs to be taken The Problem and the Direction
to move toward resolution. The discussion offers Conventional characterizations of the EIA
insights from practice (with examples from actual process, as typically portrayed in EIA literature,
EIA processes) and from theory. It then proceeds do not adequately reflect the choices available.
to suggestions for integrating solutions at the reg- At the regulatory level
ulatory and applied level, and concludes with a the tendency is to
summary of both the positive and negative as- focus on the details of
pects of the solutions suggested. existing individual EIA practitioners can benefit from a
Experiences in four jurisdictions (the United EIA systems, often for suite of EIA processes as they seek
States, Canada, Australia, and the European only a single jurisdic- to meet multiple demands and to
Union) are integrated into the analysis. tion. But EIA regula- match process and context.
tory systems are not
The EIA Process Assumes a Central Role static. Also, there may
EIA practitioners have considerable discre- be significant flaws, gaps, and inconsistencies in
tion in EIA activity sequence, in subdividing the system.
EIA activities, and in choosing activity inputs, Simply assuming (or even refining or modify-
outputs, and interconnections. The EIA process ing) the existing system may be insufficient. The
frames methods application, document prepa- benchmark should be good regulatory practice.
ration and review, decision making, and public The direction is to provide a sense of the choices
participation. It also is the primary bridge be- available for achieving good regulatory practice.
tween EIA regulatory requirements and EIA This entails both going back to first principles
practice. and drawing upon the experiences of multiple ju-
EIA practitioners can benefit from a suite of risdictions.
EIA processes as they seek to meet multiple de- At the applied level, EIA texts tend to simply
mands and to match process and context. present a single EIA process. Exhibit 2 shows an
example of such a process. What is rarely por-
A Concerted Effort Is Made to Bridge Theory trayed is the considerable potential for altering the
and Practice sequence and interconnections among activities,
The analysis seeks to narrow the gap between for subdividing or amalgamating activities, and for
theory and practice by: changing inputs and outputs. Alternative
processes and process variations, moreover, are sel-
• integrating practice-based stories, dom described, compared, or critically evaluated.

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 41
 Exhibit 2. Example of a Conventional EIA Process*

42 / Summer 2005 / Environmental Quality Management David P. Lawrence

 Occasionally, allowance is made for individ- tion and coordination functions. Integration
ual process variations. Usually, little importance and coordination encompass interrelation-
is attached to these variations. The EIA practi- ships among EIA activities (e.g., links, fre-
tioner is left in the difficult position of designing quency, sequence), integration and coordi-
and managing the EIA process without the bene- nation with international EIA activities (e.g.,
fit of an array of readily accessible process guid- development aid, global commons, neigh-
ance choices that can be integrated, combined, boring countries), vertical coordination (e.g.,
adapted, and applied to suit the circumstances. other government levels, other impact as-
The direction is to systematically present an sessment levels, government/nongovern-
array of available EIA process design and man- ment), horizontal coordination (e.g., related
agement choices. laws, related policies, plans and programs,
related projects and activities, actions by
Regulatory EIA Choices other government departments and agen-
Examples of choices available at the regula- cies), and links to the knowledge base (e.g.,
tory level include: applied environ-
mental and EIA re-
• EIA regulatory screening systems can be de- search, traditional
signed to achieve one or more of the follow- knowledge, envi- Designing and managing EIA
ing objectives: (1) incorporate environmental ronmental moni- regulatory systems necessitates
considerations into proponent decision mak- toring, interdisci- close attention to integration and
ing; (2) integrate environmental considera- plinary analysis). coordination functions.
tions into action-related decisions; and (3) EIA regulatory sys-
protect and enhance the environment. Signif- tems can be more
icance determination assumes a pivotal role effective when good practice criteria are in-
in any EIA screening system. Each screening tegrated for each integration and coordina-
system type has positive and negative attri- tion type.
butes. EIA screening systems can be improved
by thoughtfully considering the attributes of Applied EIA Choices
each screening system type and by integrating Numerous choices are available to EIA process
good practice criteria for screening type(s) managers when designing and managing EIA
and significance determination. processes, as noted in Exhibit 3. These choices
• EIA regulatory systems can be further en- pertain, for example, to:
hanced by integrating good regulatory prac-
tices into the requirements and guidance for • activities and activity components (including
the overall EIA process (e.g., objectives, mini- choices concerning activity sequence, form,
mum requirements, general performance frequency, duration, and interaction);
standards, guidelines), and for individual EIA • inputs to the process;
activities (e.g., scoping, baseline analysis, al- • outputs from the process;
ternatives analysis, impact analysis, impact • links between the EIA process and decision
management, documentation, participation). making and related activities and fields;
• Designing and managing EIA regulatory sys- • how to adapt the process for different EIA pro-
tems necessitates close attention to integra- posal, proponent, effect, and setting types;

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 43
 Exhibit 3. Process Management Elements*

• how to match proposal- and effect-specific Closing the Loop

characteristics; and EIA practitioners (at both the regulatory and
• how to integrate insights and lessons from applied levels) can make effective use of these reg-
EIA quality and effectiveness analyses. ulatory and process design choices. But the avail-

44 / Summer 2005 / Environmental Quality Management David P. Lawrence

able choices do not directly address the recurrent Others suggest that a scientific EIA approach
problems identified in this article (i.e., the need is inappropriate (because of the value-full nature
for EIA practice to be more rigorous, rational, sub- of EIA) and impractical (because decision-making
stantive, practical, democratic, collaborative, eth- needs are sacrificed in the quest to achieve unre-
ical, and adaptive). alistic—in an applied field such as EIA—scientific
Although some choices may partially address standards).
such concerns, there is no way of knowing which Still others maintain that analytical scientific
regulatory or applied choices or combination of methods and standards can be selectively ap-
choices are more or less effective in avoiding and plied, adapted, tempered, and modified to be
ameliorating the recurrent problems or problem consistent with the limits and properties of EIA
combinations. What is required then is: practice. Further complicating the issue is a
plethora of alternative
• thorough exploration of each recurrent prob- conceptions of the na-
lem, together with preliminary identification ture and role of science
of a direction for change; as it is and as it could These contextual analyses provide
• integration of insights from practice; be applied in planning the basis for regulatory and applied
• systematic review of relevant concepts and and decision-making guidance for implementing a more
frameworks; practice. scientific EIA process.
• formulation of potential regulatory reforms The direction to-
that directly address each recurrent problem; ward a more scientific
• formulation of potential EIA process reforms EIA process entails
that directly address each recurrent problem; identifying the assumptions and principles of
• systematic, consistent, and explicit evaluation analytical science and exploring the debates, to-
of potential reforms; and gether with potential middle ground, surround-
• assessment of various ways of connecting and ing if and how analytical science might be mod-
combining potential reforms to address situa- ified in general, and for applied fields such as
tions characterized by multiple recurrent EIA. These contextual analyses provide the basis
problems. for regulatory and applied guidance for imple-
menting a more scientific EIA process.
Relevant regulatory and applied choices can
then be integrated into such analyses, as appro- Insights from Practice
priate.
• A Hospital Redevelopment in London
Making EIAs More Rigorous An EIA was undertaken for a major hospital
redevelopment in London, England. The assess-
The Problem and the Direction ment of cultural heritage effects, although com-
The question of the appropriate role of sci- plying with regulatory requirements and adher-
ence in EIA practice is a controversial one. Some ing to common practice, was found lacking by a
argue that too limited a role for science in EIA review body. Supplementary, more rigorous
practice has resulted in ill-defined, biased, subjec- analysis was required.
tive, and excessively descriptive EIA processes, This example illustrates that administrators
documents, and methods. often have considerable discretion in regulatory

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 45
 interpretation, and are also well aware of the teristics of analytical science, and appreciate the
changing state of social and natural scientific nature of positions (and the middle ground be-
knowledge, methods, and practices. tween positions) associated with various scien-
Consequently, integrating contemporary sci- tific debates. Examples of insights with implica-
entific knowledge and methods into EIA practice tions for EIA practice include:
can have considerable practical value. The in-
creasing stress being placed on cumulative effects • Much thought has been given in science to
and sustainability contributions is likely to rein- concepts and mechanisms for bridging the
force the value to EIA practice of scientific per- gap between theory and applied practice
spectives and methods. (Example provided by (e.g., applied theory, grounded theory, em-
Alan Bond, School of Environmental Sciences, piricism).
University of East Anglia.) • Systematic procedures and principles have
been developed in science for moving from
• A Marina in Glenelg, South Australia the general to the particular (deduction),
An EIA for a marina in Glenelg, South Aus- and from the particular to the general (in-
tralia, was heavily crit- duction).
icized in public sub- • Some scientific characteristics closely parallel
missions because of its those of EIA practice (e.g., collective, method-
Integrating contemporary scientific failure to systemati- ological, complex, pluralistic, heuristic).
knowledge and methods into EIA cally identify, predict, • Some scientific characteristics appear appro-
practice can have considerable and interpret key ef- priate for some EIA characteristics, such as im-
practical value. fects and reasonable pact prediction and management (e.g., objec-
options, and to con- tive, independent, explanatory, verifiable),
structively involve but less appropriate for others, such as inter-
stakeholders. In order pretation and decision making.
to break the deadlock between the proponent • Certain scientific characteristics (e.g., re-
and local opposition, an independent evaluation ducible, certain, natural science model)
was undertaken to differentiate between some seem either inappropriate or highly con-
“facts” and “opinions.” This review provided the strained in the uncertain and subjective
basis for a decision by the state. world of EIA practice.
This example illustrates that sometimes a sys- • EIA, in common with applied science, seeks to
tematic and rigorous external and independent balance rigor and relevance, and to blend the
evaluation (i.e., a scientific approach) can provide objective with the subjective, the espoused
a sound decision-making basis, even in highly with the applied, the explanatory with the
polarized situations. (Example provided by Nick prescriptive, and analysis with synthesis. EIA,
Harvey, Department of Geographical and Envi- also in common with applied science, at-
ronmental Studies, University of Adelaide.) tempts (not always successfully) to be benefi-
cial to the environment, and to democracy.
Insights from Theory Depending on the situation, a “predict and
In order to establish a sound foundation for a control” or a “manage and adapt” approach
scientific EIA process, it is helpful to understand can be more appropriate in both EIA practice
key scientific terminology, recognize the charac- and applied science.

46 / Summer 2005 / Environmental Quality Management David P. Lawrence

• Because of the importance of local circum- Integrating Rigor at the Applied Level
stances, and of value and perspective differ- Exhibit 4 offers an example of a scientific
ences, EIA practice seems to correspond EIA process. Major features include the following:
more closely to a pluralistic rather than a
unified scientific approach (i.e., competing • The process treats EIA practice as an experiment.
and overlapping integrative frameworks and • The process is structured by an experimental
concepts). design.
• The baseline analy-
Integrating Rigor at the Regulatory Level sis applies multiple
Measures that can be introduced at the regu- and reliable envi-
latory level to contribute to more rigorous EIA ronmental criteria Undertake EIA quality and
practice include: or indicators to effectiveness analyses to help build
provide a dynamic and test a core body of good
• Identify general science-related principles picture of trends practice.
for application in EIA practice (e.g., inter- and patterns, and
disciplinary, unbiased language, methods to identify sensi-
accepted by scientific community, confi- tive and significant environmental compo-
dence limits, determination of Type I and nents, functions, and processes.
Type II statistical errors, use of scientific no- • Predictions are deduced from hypotheses and
tations). alternatives.
• Sponsor research to address knowledge and • Models and theories trace causal connections.
methodological gaps. • Hypotheses are tested by comparative, con-
• Undertake EIA quality and effectiveness trol, case, and pilot studies prior to approval,
analyses to help build and test a core body of and by monitoring and follow-up studies after
good practice. approval.
• Promote science-based and adaptive manage- • Gaps, limits and uncertainties, and associ-
ment approaches. ated implications are explicitly considered.
• Accredit environmental professionals. • Interpretations are explicitly substantiated,
• Promote use of scientific panels and advisors. preferably by statistical analyses.
• Formulate science-related methodological • Scientists and natural and social scientific
guidance for specific EIA activities (e.g., knowledge are central to the process.
forecasting), environments (e.g., ecological
processes), and effects (e.g., cumulative Positive and Negative Aspects of Making EIAs
effects). More Rigorous
• Establish interagency scientific task forces or On the plus side:
committees (e.g., to guide the assessment of
social or ecological effects, to prepare hand- • A scientific EIA approach effectively inte-
books, to facilitate the use of scientific meth- grates scientific knowledge, methods, and
ods, frameworks, or approaches). standards.
• Prepare scientific research guidelines (e.g., in • It facilitates participation by scientists, builds
environmentally sensitive areas, for involving on the natural and social knowledge base, and
indigenous peoples). establishes links to the scientific community

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 47
 Exhibit 4. Example of a Scientific EIA Process*

through literature reviews, peer review proce- • Scientific practice tends to be focused, sys-
dures, and the circulation and publication of tematic, efficient, explicit, unbiased, iterative,
findings and methodological adaptations. interactive, and adaptive.

48 / Summer 2005 / Environmental Quality Management David P. Lawrence

 On the minus side: definitions and applications, and integrating
these adaptations into EIA requirements and
• Scientific approaches are less suited to “value- processes.
full” EIA activities (e.g., issue and option
analysis, option evaluation, significance inter- Insights from Practice
pretation).
• They can be biased toward the readily meas- • A Hazardous Waste Landfill near Sarnia,
urable. Sometimes limitations and uncertain- Ontario
ties are underestimated. An EIA was prepared for the enlargement of a
• Nonscientific knowledge tends to be dis- private hazardous waste landfill near Sarnia, On-
counted. The public is often peripheral to the tario, Canada. The EIA documentation used
process. largely qualitative (but
• Fairness, equity, and environmental justice is- fully substantiated)
sues and perspectives are not directly ad- scaling procedures to
dressed. systematically, explic- Rationality can either be a positive
• Scientific EIA practice can stress the analytic itly, and consistently or a negative force in an EIA
over the integrative and holistic. address the purpose of process, depending on one’s
the process and pro- perspective.
posal, reasonable alter-
Making EIAs More Rational natives, individual and
cumulative effects, im-
The Problem and the Direction pact management measures, and public and
Rationality can either be a positive or a nega- agency concerns and preferences.
tive force in an EIA process, depending on one’s The methods for conducting the alternatives
perspective. To its proponents, the problem is the and site assessment analyses did not become is-
failure of EIA practice to measure up against ra- sues for either the public or for government re-
tionality ideals (e.g., being comprehensive, con- viewers. The public and agencies instead fo-
sistent, explicit, traceable). cused on the prediction and management of a
By contrast, critics argue that EIA practice is or few key impacts. Both public and agency con-
strives to be too rational. Rational processes are cerns were resolved to the satisfaction of most
characterized as politically naïve, impractical (in parties, and the project was approved without a
terms of recognizing decision-making limita- public hearing.
tions), inflexible, poorly equipped to deal with The systematic and traceable analysis of alter-
uncertainty and subjectivity, and prone to tech- natives and impacts was not responsible for proj-
nocratic and autocratic tendencies. ect approval. But this analysis made it possible for
A third group of commentators suggests that the interested and affected parties to focus on and
rationality can be appropriate if rationality stan- resolve a small number of manageable issues. (Ex-
dards are adapted and refined to match contex- ample provided by author.)
tual conditions, constraints, and uncertainties.
The direction involves applying valid ration- • Landfill Siting in Metropolitan Toronto
ality strengths, minimizing legitimate rationality A special authority was established to locate
deficiencies, drawing upon alternative rationality suitable landfill sites in three regions surrounding

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 49
 metropolitan Toronto. Highly technical and • There are many rationality forms (e.g., instru-
largely quantitative evaluation procedures were mental, procedural, substantive, social,
used to screen and compare areas and sites. bounded, communicative). These rationality
Heavy reliance was placed on expert judgment. forms can help define, bound, focus, and
The role of the public was limited to reacting to shape the treatment of rationality in the EIA
the consultant analyses and contributing to crite- process.
ria group and criteria rankings and weightings. • Rational processes tend to assume that prob-
The process generated a storm of protest and lems are well defined, that the environment
was eventually abandoned. The local public ques- and available choices are predictable and con-
tioned the legitimacy of the assumptions, the trollable, that a uniform public interest can be
logic of the discipli- defined, and that decision makers are ra-
nary distinctions, the tional. There is some potential for relaxing
A rational EIA process should abstract ranking and and adapting such assumptions.
exhibit characteristics such as weighting procedures, • A rational EIA process clearly defines the
being purposeful, orderly, logical, and the failure to ef- problem; explicitly identifies goals and ob-
coherent, explicit, consistent, fectively integrate jectives; consistently, explicitly, and system-
reflective, and reasonable. local knowledge and atically evaluates alternatives against goals
adequately tailor the and objectives; integrates the process into
procedures to regional planning and decision making; and imple-
characteristics. ments and monitors the preferred alterna-
A truly rational EIA process effectively inte- tive. The process is supported by sound
grates local perspectives and knowledge and is ap- technical analyses and judgments. Agencies
propriate to the context. (Example provided by and the public provide inputs prior to major
author.) decisions.
• Many strengths (e.g., being simple, explicit,
Insights from Theory logical, systematic, adaptable) and limitations
Rational EIA processes can be more effec- (e.g., being unrealistic, ineffective, incom-
tively formulated when based upon a sound un- plete, inappropriate) have been attributed to
derstanding of rationality attributes, forms, as- rational planning and decision making. These
sumptions, core characteristics, strengths, strengths and limitations are tendencies that
limitations, and approaches for oversetting lim- can be offset or reinforced.
itations. Source materials suggest, for example, • Several responses to the limitations of rational
that: planning have been formulated (e.g.,
bounded rationality, strategic planning, effec-
• A rational EIA process should exhibit charac- tive planning, advocacy planning, commu-
teristics such as being purposeful, orderly, log- nicative planning). These responses have
ical, coherent, explicit, consistent, reflective, sought to make the process more realistic, ef-
and reasonable. fective, open, democratic, and substantive.
• Rationality attributes function best when sup- • EIA literature partially mirrors, and has par-
ported by grounds (such as evidence, analysis, tially drawn upon, these larger rationality-
and methods) and when key preconditions related debates. EIA practice could benefit
(such as openness and trust) are satisfied. from a closer scrutiny of these debates.

50 / Summer 2005 / Environmental Quality Management David P. Lawrence

Integrating Rationality at the Regulatory • The process is bounded by scoping, and by ex-
Level plicitly considering internal and external con-
Measures that can be introduced at the regu- straints and opportunities.
latory level to contribute to more rational EIA • The proposed action is described, together
practice include: with potentially reasonable alternatives.
• Alternatives are first screened using exclusion-
• Require the consideration of reasonable alter- ary criteria.
natives. • Reasonable alternatives are compared against
• Provide guidance for differentiating reason- objectives using evaluation methods, which
able from unreasonable alternatives (i.e., combine scaled effects with criteria rankings
screening procedures and criteria). and weightings.
• Require evaluation of the environmental con- • Uncertainties and value variations are ad-
sequences of alternatives. dressed through sensitivity analyses.
• Identify the types of alternatives that must, • Baseline conditions are systematically charac-
should, and may (depending on the situation) terized.
be considered. • Individual and cu-
• Include more requirements and recommenda- mulative impacts,
tions regarding alternatives to be considered with and without Identify the types of alternatives
in proposal- and location-specific require- mitigation, are sys- that must, should, and may
ments and guidelines. tematically identi- (depending on the situation) be
• Require that the proposal purpose and need fied, predicted, and considered.
be addressed. Require the linking of the pro- interpreted. Impact
posal purpose and goals to the purpose and magnitude and sig-
goals of the EIA legislation. nificance ratings are qualitatively or quantita-
• Provide guidance for facilitating the system- tively scaled and amalgamated.
atic, explicit, and consistent identification, • A comprehensive impact management pro-
evaluation, and management of alternatives gram is formulated.
and impacts. • The process is supported by technical studies,
• Ensure that requirements and guidelines are reviews of comparable proposals and environ-
sufficiently flexible to retain and foster rea- ments, peer reviews, and applied research.
soning in EIA processes, without precluding • The public identifies concerns and suggestions
the potential contributions from variations of and responds to analyses and documents.
and alternatives to rationality. • Documents are expected to provide a clear,
unbiased, systematic, and accurate decision-
Integrating Rationality at the Applied Level making basis.
Exhibit 5 offers an example of a rational EIA
process. Major features of the process include: Positive and Negative Aspects of Making EIAs
More Rational
• The problem or opportunity is clearly char- On the plus side:
acterized.
• The purpose, goals, objectives, and principles • Rational EIA processes tend to be consistent
are systematically determined. and systematic. Options, effects, and manage-

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 51
 Exhibit 5. Example of a Rational EIA Process*

ment methods are systematically generated, • Rational EIA processes are supportive of the in-
assessed, and applied. tegration and application of scientific and
• Relevant physical, biological, social, cultural, technical knowledge, methods, and standards.
and economic effects can be effectively incor- • A clear and traceable decision-making basis is
porated into a rational EIA process. generally provided.

52 / Summer 2005 / Environmental Quality Management David P. Lawrence

 On the minus side: processes, or only minor process refinements
are necessary);
• Rational EIA processes tend not to be con- • moderate adjustments are needed (i.e., by
ducive to holistic perspectives, can emphasize adopting good practices and through greater
process over substance, can discount non- emphasis on positive substantive out-
technical and extrarational environmental comes); and
knowledge and forms, and can sometimes • major reforms are needed (e.g., redesign EIA
sacrifice practicality in the drive to be com- processes to facilitate the integration of sub-
prehensive. stantive concerns, to reinforce environmen-
• The emphasis on technical and scientific tal values, to overcome implementation
knowledge, methods, and analysis can inhibit constraints and knowledge limits, and to
local democratic control and collaborative ef- better link EIA to larger frameworks and
forts, relegate equity and fairness to second- other methods).
ary concerns, and undermine boundary-
spanning efforts (e.g., among knowledge The process-substance problem varies among
forms, across varying perspectives and ideals, ecological, social, and
and to other professions and environmental sustainability con-
management types). cerns. Many un- It must be assumed that all problem
• Rational EIA processes in practice can be in- knowns remain re- perspectives and solutions,
flexible, and often are poorly adapted to com- garding process and depending on the circumstances
plex and uncertain situations. substance links and and to varying degrees, are valid.
the outcome effective-
Making EIAs More Substantive ness of alternative EIA
processes.
The Problem and the Direction Pending such knowledge, it must be assumed
The relationships between process and sub- that all problem perspectives and solutions, de-
stance in EIA practice can be approached from pending on the circumstances and to varying de-
many perspectives. These perspectives include grees, are valid. The direction then is to explore
the following: how EIA process management can better address
this constellation of interrelated problems and
• process and substance should be kept separate solutions.
(because EIA wastes resources or reinforces the
status quo, or because substance is the role of Insights from Practice
other tools and EIA should focus on process);
• the role of the EIA process in contributing to • A Waste Management Facility in Stryria,
substantive environmental improvements is Austria
unknown (because decision-making, out- An EIA was completed successfully for a waste
come, and environmental characteristics are management facility in Stryria, Austria. The pro-
unknown), and the priority should be on ac- posed facility would employ mechanical and bio-
quiring such knowledge; logical waste treatment methods. During the
• minor refinements are needed (i.e., substance process, several citizens founded a group to facil-
can be readily integrated into conventional itate public participation. The group worked

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 53
 closely with the developer and the environmen- EIA process. (Example provided by Jo Anne Beck-
tal authority. They thoroughly and critically re- with, Department of Resource Development,
viewed the EIA documentation. They were able to Michigan State University.)
strongly influence the EIA decision-making
process and contributed to essential substantive Insights from Theory
environmental changes. An appreciation of substantive (ecological, so-
This example demonstrates that a more sub- cial, sustainability) concepts can aid in establish-
stantive EIA process can result from enhanced ing a firm foundation for enhanced EIA process
public participation and influence, which broad- management. Examples of the implications for EIA
ens and reorients the process to better accommo- practice of these concepts include the following.
date a wider range of substantive knowledge and
insights. (Example provided by Ralf Aschemann, • Ecological concepts demonstrate the need:
Austrian Institute for the Development of Envi- ◆ for an ecological systems perspective;
ronmental Assessment.) ◆ for a place-based approach;
◆ to integrate sound ecological knowledge;
• A Marina Complex in Mandurah, Western ◆ to transcend disciplinary boundaries;
Australia ◆ to recognize ecological stresses and limits;
A major new marina complex was proposed ◆ to acknowledge limits on knowledge and
for the coastal and control;
holiday community of ◆ to manage impacts continuously and
An appreciation of substantive
Mandurah in Western adaptively; and
(ecological, social, sustainability)
Australia. As part of ◆ for the process to be open, adaptive, cre-
concepts can aid in establishing a
the impact assessment ative, collaborative, iterative, selective,
firm foundation for enhanced EIA
process, the regional and action-oriented.
process management.
development commis- • Social concepts illustrate the need to:
sion hired a consult- ◆ recognize that people react in anticipa-
ant to undertake a so- tion of, and adapt to, change;
cial impact assessment (SIA) of the marina ◆ appreciate that social phenomena are
proposal as it related to the permanent residents very difficult to forecast and influence in
of a caravan park. predictable ways;
The SIA drew heavily on the psychology and ◆ be aware of the multiple potentially ap-
sociology literature. The SIA was able to effec- plicable (but partially overlapping and
tively characterize and legitimize the perspectives conflicting) social models, theories, per-
and perceptions of the park residents. It also spectives, and frameworks;
raised important issues, facilitated the explo- ◆ offset the often peripheral position of
ration of management options, and gave the SIA in decision making;
local residents a greater sense of control over ◆ be cautious regarding preconceptions;
their destinies. ◆ appreciate the implications of the gulf
This example demonstrates that the appropri- between the social sciences and applied
ate use of social scientific methods by qualified fields such as SIA;
SIA professionals can help integrate substantive ◆ design and adapt the process to fit the
insights and constructive suggestions into the context;

54 / Summer 2005 / Environmental Quality Management David P. Lawrence

 ◆ see the world through the eyes of poten- ◆ managing uncertainty; and
tially affected parties; ◆ facilitating the involvement of interested
◆ socially construct the EIA process; and potentially affected parties.
◆ explore social impacts at multiple levels
and from multiple perspectives; Integrating Substance at the Regulatory Level
◆ recognize that meaning and value are so- Measures that can be introduced at the regu-
cially determined; and latory level to contribute to more substantive EIA
◆ facilitate a central role for dialogue and practice include:
social interaction in the process.
• Sustainability concepts underscore the need to: • Ensure that social, ecological, and sustainabil-
◆ be aware of the varying perceptions of ity goals and principles are incorporated into
the nature and purpose of sustainability; EIA legislation and strategic environmental
◆ take into account that sustainability is assessment (SEA) requirements.
refined through sustainability forms and • Define the environment broadly, and require
ethical perspectives; directed by needs, consideration of di-
aspirations, and principles; applied rect and indirect,
through instruments, procedures, and short- and long- Require that proposed actions be
processes; integrated by strategies, vi- term ecological, re- assessed in terms of the extent to
sions, and frameworks; and adapted to source, social, cul- which they contribute to or detract
contexts; tural, heritage, from the substantive goals of the
◆ integrate sustainability at conceptual, health, economic, EIA legislation.
regulatory, and applied levels; and transboundary (in-
◆ ensure an effective role for sustainability cluding global com-
in interpreting significance; determining mons), and cumulative effects.
environmental limits; integrating envi- • Explicitly identify substantive priorities in EIA
ronmental change measures; interpret- legislation (e.g., matters of national environ-
ing present conditions; determining mental significance). Provide detailed require-
plausible, planned, and desired futures; ments and guidelines for addressing potential
managing environmental change; estab- impacts on each priority substantive concern.
lishing links to other environmental • Require that proposed actions be assessed in
management instruments; and advanc- terms of the extent to which they contribute
ing substantive EIA aspirations. to or detract from the substantive goals of the
• Substantive methods can aid in: EIA legislation.
◆ addressing interrelationships; • Use guidelines to address the treatment of
◆ characterizing and interpreting past and various types of substantive effects.
present conditions; • Coordinate the treatment of substantive envi-
◆ identifying ecological and social limits; ronmental concerns with interagency com-
◆ portraying plausible and desirable future mittees, task forces, and procedural guidance,
conditions; and among government levels (e.g., tiering).
◆ determining how to narrow the gaps be- • Sponsor applied research on substantive envi-
tween plausible and desirable future ronmental issues and methods (e.g., ecologi-
conditions; cal management, SIA, adaptive management).

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 55
 • Place treatment of substantive concerns • These analyses provide the basis for decision
through EIA requirements within the context making.
of broader (e.g., international, national, inter- • Outcomes are monitored and linked to sus-
agency) substantive legislation, strategies, tainability and environmental indicators.
plans, policies, frameworks, and monitoring
systems. Positive and Negative Aspects of Making EIAs
• Systematically assess the effectiveness of reg- More Substantive
ulatory efforts to integrate EIA process and On the plus side:
substance.
• An EIA process focused on tangible environ-
Integrating Substance at the Applied Level mental improvements is consistent with a ho-
Exhibit 6 offers an example of a substantive listic scientific approach.
EIA process. Major features include the following: • It is conducive to achieving substantive ob-
jectives.
•
The process operates within the context of • It effectively addresses interrelationships.
sustainability plans, strategies, constraints, • It can integrate multiple values, forms of
and opportunities. knowledge, perspectives, and ideals.
• Models, scenarios, visions, and stories are • It can facilitate local influence and procedural
used to construct plausible and desired fu- and distributional fairness.
tures, recognizing alternative worldviews and • It is usually collaborative, open, flexible, in-
value positions. terdisciplinary, and linked to related environ-
• Gaps between plausible and desired futures are mental management and sustainability in-
determined. The gaps struments.
provide the basis for
An EIA process focused on tangible first identifying sus- On the minus side:
environmental improvements is tainability principles,
consistent with a holistic scientific goals, objectives, and • Sometimes, inconsistencies arise in the com-
approach. priorities, and then es- plex task of drawing together diverse methods
tablishing specific sus- and perspectives.
tainability targets, cri- • Such processes can be difficult to follow and
teria, and thresholds. manage, and can be hampered by complexity,
• Alternatives for closing the gaps are identified. a broad level of detail, political naïveté, and
Proposed actions and alternatives are refined insufficient attention to short-term require-
and treated as potential sustainability catalysts. ments, institutional barriers, and regulatory
• Alternatives are evaluated against sustainabil- perspectives.
ity thresholds, and in terms of the extent to • The process can break down in highly polar-
which they contribute to or undermine sus- ized situations or if expectations regarding
tainability objectives. what can be practically achieved are raised to
• The individual and cumulative effects of the unrealistic levels.
selected action are identified, predicted, inter- • Determining the appropriate contributions of
preted, and managed, again with the empha- individual proposals to environmental and
sis on furthering sustainability. sustainability targets can be problematic.

56 / Summer 2005 / Environmental Quality Management David P. Lawrence

 Exhibit 6. Example of a Substantive EIA Process*

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 57
 Making EIAs More Practical employed a system of indicators to measure “the
state of the culture.”
The Problem and the Direction This example demonstrates that practicality
Practicality, in the EIA process, concerns can be an outcome from a collaborative planning
whether the process is focused, realistic (consistent process structured and managed to provide prac-
with how policy making and decision making take tical solutions to real stakeholder problems. (Ex-
place), feasible (with proposed and assumed ac- ample provided by Annie Holden, ImpaxSIA
tions that can be undertaken and implemented in Consulting, Brisbane, Australia.)
varying contexts), competent (consistent with
good practice performance standards), and effec- • Oil Sands Development Projects in the
tive (so that it realizes its potential). Fort McMurray Region, Alberta
The problem is that Oil sands development projects in the Fort Mc-
EIA processes tend to Murray region of Alberta, Canada, have to meet
be unfocused, discon- both provincial and federal EIA requirements. The
EIA processes tend to be unfocused, nected from reality, Terms of Reference (TORs) for each project have
disconnected from reality, weak on weak on implementa- tended to include lengthy lists of requirements, re-
implementation, of variable quality, tion, of variable qual- sulting in costly and time-consuming EIA processes.
and slow to learn from experience ity, and slow to learn Shell Canada has developed a focused TOR
and practice. from experience and that, in combination with a strategic-level EIA ap-
practice. The direction proach, has resulted in much more focused (and
is advancing toward less time-consuming and costly) EIAs, without
making the EIA process more focused, relevant, sacrificing the integrity of the process or environ-
feasible, competent, and effective. mental outcomes. Regulatory agency cooperation
was critical in this effort.
Insights from Practice The process highlighted in this example ap-
plied a practical method (scoping) to counteract
• Management Plan for the Ulura Kata Tjuta engrained perspectives and behaviors, producing
National Park in Central Australia a more efficient EIA process that did not jeopar-
A social and cultural impact study was under- dize either substantive environmental objectives
taken as part of a management plan for the Ulura or stakeholder interests. (Example provided by
Kata Tjuta National Park in Central Australia. The Roger Creasey, Shell Canada Ltd.)
SIA served to identify the impacts of tourism and
national park management on the local commu- • Class Screening under the CEAA
nity of indigenous traditional owners. The con- Most projects and activities that trigger an en-
sultant used a range of participative SIA methods vironmental assessment under the Canadian Envi-
to derive practical strategies that addressed the ronmental Assessment Act (CEAA) are assessed
concerns and aspirations of traditional owners through self-directed screening. The CEAA provides
and stakeholder groups. for a class screening mechanism to streamline and
These strategies were incorporated into the simplify the regulatory review and approval process
five-year management plan. Many measures were for routine or repetitive projects or activities.
implemented immediately. A monitoring and Class screening is expected to result in more
evaluation framework was also developed that predictable, efficient, and certain EIA processes.

58 / Summer 2005 / Environmental Quality Management David P. Lawrence

Although the general trend in the use of class as- requirements. It cuts across disciplines and
sessments has been positive, outcomes in terms of professions.
greater efficiency have been mixed or uncertain. • Practical EIA processes are competent. Partici-
This example demonstrates that applying a pants are qualified. Roles are clearly defined
regulatory streamlining procedure, such as class and well coordinated. Good practices are em-
screening, does not necessarily create only bene- ployed in the conduct of individual and joint
fits; there also can be negative implications. Seri- EIA activities. Recurrent competence-related
ous obstacles can be encountered. And the proce- problems are avoided or minimized.
dure is only effective if cautiously applied, • Practical EIA processes are effective. Effective-
thoughtfully adapted and refined to suit the situ- ness addresses how well the process works. It
ation, and monitored for effectiveness. (Example concerns the quality of inputs and the effec-
provided by Lesley Matthews, Jacques Whitford tiveness of direct and indirect outputs. EIA
Environment Limited.) quality and effectiveness analyses raise the level
of EIA practice, distinguish between accept-
Insights from Theory ability and performance levels, correct deficien-
Practical EIA processes are focused, realistic, cies, involve inter-
feasible, competent, and effective. Source materials ested and affected
related to these themes suggest, for example, that: parties, substantiate Practical EIA processes are focused,
interpretations and realistic, feasible, competent, and
• The EIA process should focus on what is im- conclusions, and fa- effective.
portant by applying scoping to EIA institu- cilitate the imple-
tional arrangements and documents, as well mentation of im-
as to EIA activities, inputs, and outputs. Scop- provements.
ing is based on clear principles, concentrates
on what is important, defines clear roles, and Integrating Practicality at the Regulatory Level
is adapted to context. Measures that can be introduced at the regu-
• A realistic EIA process is grounded in prac- latory level to contribute to more practical EIA
tice and experience. It is based on a sound practice include the following:
understanding of organizational structures
and procedures; how decisions are made; • Minimize EIA duplication and overlap among
how practitioners operate; how people be- government levels by:
have in organizations; how power is exer- ◆ clearly defining environmental responsi-
cised; how resources are allocated; and how bilities (e.g., matters of national environ-
actions are implemented, facilitated, inhib- mental significance);
ited, and prevented. ◆ employing joint processes, documents,
• A practical EIA process is workable. It can be and public hearings;
undertaken and implemented. It is informed ◆ using interagency and intergovernmental
by concepts; guided by strategies; aided by agreements, committees, and task forces;
tactics, tools, and methods; and merged with ◆ sharing databases and coordinating review
implementation, management, and context. procedures and review schedules;
It is linked to other decision-making levels, to ◆ undertaking joint place-based planning
related instruments, and to other government and management;

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 59
 ◆ employing accreditation, equivalency, del- ment circulation limits, quick-test triggers,
egation, or lead government systems; and and accelerated project planning;
◆ defining minimum levels of good practice, ◆ accelerating the review process with
using tiering, and cross-referencing related checklists, electronic registries, and clearly
requirements. defined standards and performance crite-
• Ensure that EIA roles among government de- ria; and
partments and agencies are well coordinated by: ◆ reducing paperwork with page limits,
◆ specifying roles, requirements, and proce- combined documents, tiering, cross-
dures in legislation, regulations, and referencing, and document content, style,
guidelines; summary, and appendix requirements.
◆ addressing joint triggering of EIA and • Ensure a minimum level of EIA competence,
other requirements and contribute to enhanced EIA practice, by:
with coordinated tim- ◆ undertaking effectiveness reviews of the
Focus on what is important and
ing, merged require- EIA system;
minimize unnecessary costs and
ments, joint docu- ◆ establishing EIA quality improvement
delays by using screening
ments, substitution teams;
procedures to focus the system on
agreements, tiering, ◆ providing for independent review of EIA
significant proposals.
cross-referencing, in- process management practices;
teragency offices and ◆ undertaking effectiveness reviews of EIA
agreements, and circu- legislation, regulations, guidelines, and
lation requirements; procedures;
◆ using coordinating agencies and EIA ◆ undertaking quality reviews of EIA docu-
process managers; ments and processes;
◆ undertaking training sessions and establish- ◆ preparing annual reports on the imple-
ing workshops, task forces, and committees; mentation of EIA requirements;
◆ building coordination around a common ◆ preparing quarterly reports on EIA lessons
purpose or within the context of larger learned;
policies or plans; and ◆ undertaking compliance monitoring;
◆ employing common databases, joint ap- ◆ monitoring EIA contributions to better
plied research, and shared or common fol- project planning;
low-up or auditing procedures. ◆ monitoring the significant effects resulting
• Focus on what is important and minimize un- from implementation of proposed actions;
necessary costs and delays by: ◆ monitoring the environmental record of
◆ using screening procedures to focus the proponents;
system on significant proposals; ◆ providing minimum requirements and
◆ providing for different types of assess- good practice guidance;
ment, and for class and categorical assess- ◆ enhancing competence levels through
ments to address degrees of significance; sponsored and coordinated research, EIA
◆ employing scoping and significance re- training, shared databases, and place-
quirements, procedures, and guidelines; based management;
◆ reducing the likelihood of delays with ◆ instituting a quality assurance program; and
time limits, suggested timelines, docu- ◆ establishing EIA centers and institutes.

60 / Summer 2005 / Environmental Quality Management David P. Lawrence

Integrating Practicality at the Applied Level • It is conducive to stakeholder involvement
Exhibit 7 offers an example of a practical and is built around decisions.
EIA process. Major features of the process include • It involves debate, discussion, negotiation, re-
the following: view, reflection, analysis, synthesis, compari-
son, and bargaining among interested and af-
• The process focuses from the outset on fected parties.
regulatory requirements and stakeholder • It integrates ends, means, constraints, analy-
issues. ses, knowledge, methods, skills, experience,

Exhibit 7. Example of a Practical EIA Process*

Environmental Impact Assessment: Practical Solutions to Recurrent Problems, Part 1 Environmental Quality Management / Summer 2005 / 61
 uncertainties, requirements, perspectives, and (though usually as a means and in response to
concerns. external pressures).
• The process operates within available resources, • Local influence, stakeholder collaboration,
is iterative and incremental, defines roles and re- and procedural and substantive fairness are
sponsibilities, explores consequences and impli- facilitated (though only when raised by stake-
cations, provides a rationale for interpretations holders).
and conclusions, and is adapted to context.
• The process is merged with approvals and im- On the minus side:
plementation and evaluates the effectiveness
of direct and indirect outputs. • Matters other than regulatory, decision-
• It is supported by experience and practice- making, and implementation concerns are
based knowledge and applies experiments, addressed selectively, if at all.
pilot projects, feasibility analyses, and tar- • Practical EIA processes tend not to be well
geted research to refine and test interpreta- adapted to major changes with long-term im-
tions and conclusions. plications.
• Close contact is maintained with interested • Scientific standards are generally not main-
and affected parties, with the focus on issues tained unless identified in regulatory require-
and perspectives directly bearing on decision ments and in good practice standards.
making and implementation. • Environmental substance is integrated only as
a means and only in response to external
Positive and Negative Aspects of Making EIAs pressures.
More Practical • Local influence, stakeholder collaboration,
On the plus side: and procedural and substantive fairness are
facilitated only when raised by stakeholders.
• Practical EIA processes are generally efficient • The narrow focus on decision making and im-
and effective in meeting decision-making and plementation can inhibit integration within
implementation needs and requirements. synthesis frameworks.
• The process is integrated with project plan-
ning, decision making, management, and im- Next Time
plementation. In the next issue of this journal, Part 2 of this
• Regulatory, decision-making, and implementa- article will address how to make EIAs more dem-
tion concerns are addressed comprehensively. ocratic, collaborative, ethical, and adaptive.
• Practical EIA processes are generally open and
References
flexible.
Lawrence, D. P. (2001). Choices for EIA process design and
• Scientific standards are maintained to the ex- management. Journal of Environmental Assessment Policy
tent that they are identified in regulatory re- and Management, 3(4), 437–464.
Lawrence, D. P. (2003). Environmental impact assessment—
quirements and in good practice standards.
Practical solutions to recurrent problems. New York: John
• Environmental substance is integrated Wiley & Sons.

David P. Lawrence, PhD, has been an EIA practitioner for more than 25 years, and is president of Lawrence Environmental
in Langley, British Columbia. He is also a member of the Planning Institute of British Columbia, the International Associa-
tion for Impact Assessment, and the National Association of Environmental Professionals.

62 / Summer 2005 / Environmental Quality Management David P. Lawrence