SCOPE 5 - Environmental Impact Assessment

A2.1 INTRODUCTION

Described below are the current EIA procedures in Australia, Canada, Japan, the UK and the USA. These examples illustrate a variety of national responses to the widespread concern about the environmental impacts of development. Differences in response are due in large part to differing political systems.

For a country contemplating the adoption of an impact assessment procedure for the first time, the best advice is to relate the procedure to the political and socio-economic structure of the country. For example, the degree of centralization/ decentralization would matter greatly in the selection of an effective EIA procedure.

A2.2 ENVIRONMENTAL IMPACT ASSESSMENT PROCEDURES IN AUSTRALIA

John Form by, Centre for Resource and Environmental Studies, The Australian National University, Canberra, Australia

A 2.2.1 Introduction

Under the Australian federal system, the Commonwealth government has only limited powers to legislate for environmental protection. Most such powers rest with the States. The Commonwealth, however, has exclusive control over the federal territories, and has other environmentally significant powers. Some of these powers can affect environmental management in the states, e.g., the ability to fund specific programmes conditionally and to control certain exports.

Both the Commonwealth and the states thus play important roles in environmental management. To give a balanced picture, the approaches to EIA at both levels of government should be fully examined. In this brief review, however, the main emphasis is placed on the Commonwealth procedures, supplemented by some short comments about those of the States. The final section provides an evaluation of the Australian experience with EIA to date.

A2.2.2 The Commonwealth Procedures

The Commonwealth first announced an EIA policy in 1972. The requirement was limited to the preparation of Environmental Impact Statements (EISs) for environmentally important Cabinet decisions. In December 1974 the Commonwealth Environment Protection (Impact of Proposals) Act came into force. The objective of the Act is 'to ensure to the greatest extent practicable, that matters affecting the environment to a significant extent are fully examined and taken into account' in relation to a complete range of activities, including proposals, works, agreements, decisions, and expenditure, where these are carried out by, on behalf of, or in conjunction with, the Commonwealth government.

Major provisions of the Act are that:

• administrative procedures may be prepared incorporating detailed requirements for environmental impact assessment; 
• each Minister must ensure that the administrative procedures are given effect and that any final EIS is taken into account by the departments or authorities for which he is responsible; 
• a public inquiry may be initiated into any matter within the scope of the Act, whether or not an EIS has been prepared. 

The provision for separate administrative procedures allows greater flexibility , in that they may be changed without undergoing the full parliamentary processes required for legislative amendment, although proposed changes are subject to parliamentary review. The administrative procedures were promulgated in July 1975. In simplified form , the main steps in the procedures are: 

• the Minister responsible for an environmentally significant proposed action designates the proponent (generally the person or department responsible for the proposed action); 
• the proponent submits specified information about the proposed action to the department administering the Act 'as soon as possible after a proposed action has been first formulated'; 
• this information is assessed and a decision made as to whether or not an EIS is required ;
• the proponent prepares a draft EIS in accordance with guidelines which set out the matters it must cover; 
• with certain exceptions, the draft EIS is made available for public comment for a minimum of 28 days; 
• a final EIS is prepared by the proponent, taking into account public comment, and is submitted to the administering department for examination; 
• the administering Minister or his department may require additional information before making any 'comments, suggestions or recommendations thought necessary or desirable for the protection of the environment'; 
• each Minister must ensure that the final EIS and any suggestions or recommendations are taken into account in matters to which they relate.

In the first two years of operation, approximately 6,400 proposals were examined, of which 650 were considered to be of environmental  significance. Following detailed review of these latter proposals, it was decided that most of them were not of sufficient environmental  importance to warrant the preparation of an EIS, often after agreement by the proponent to implement certain environmental protection measures. Thirty-three EISs were formally directed and two public enquiries initiated during the period.

The Act and the administrative procedures do not require that projects should be environmentally sound, nor do they provide any power to withhold approval on environmental grounds. They require only that the environmental consequences of proposed actions are fu1ly considered, and to this end they simply provide the framework for a process of obtaining and reviewing information.

This approach is reinforced by the ample provisions of the legislation for the exercise of political and administrative discretion. Subject to various matters to be 'taken into account', the administering Minister is empowered to determine whether an EIS is required; the matters it is to examine; whether a draft EIS is to be made available for public comment; whether additional information is required; and whether a public inquiry is to be held. Furthermore, the Minister may exempt any proposed action or class of actions from the requirements of the procedures, with the proviso that he must have regard to the general principle that in the national interest the procedures should be applied as far as possible to all proposed actions. With the aid of such provisions, the legislation has so far largely avoided a role for the Courts in defining or enforcing its requirements.

Because of the latitude provided for administrative discretion, and because the procedures are designed to cover the whole range of government activity, they do not provide precise answers about their application in specific circumstances. Accordingly, 'memoranda of understanding' between the administering Minister and those of other Commonwealth departments are being developed in order to define how the Act is to be applied to particular Ministerial portfolios. Agreements are also proposed, and in some cases have been concluded, between the Common-wealth and the States to clarify their respective responsibilities for EIA.

A2.2.3 State Procedures 

Unlike the Commonwealth, none of the six States has yet passed legislation directly embodying its EIA procedures. Most State procedures, however, are given various degrees of indirect support by legislation for land-use planning and pollution control. Although the main features of most State procedures bear a family resemblance to those of the Commonwealth, there are considerable variations both amongst the procedures themselves and in the extent of their implementation.

New South Wales has had the longest and most extensive experience with EIA and environmental inquiries. An environmental  impact policy was announced early in 1972 and formal procedures were introduced in 1973. The procedures have since been extensively revised. The current procedures, issued in October 1974, contain some provisions which differ notably from those of the Commonwealth. There is no requirement in the New South Wales procedures for 'draft' and 'final' EISs. The determining authority must 'seek and take into account' public comment on the EIS, but it need not be revised.

Administration of the New South Wales procedures is more decentralized than in the case of the Commonwealth. The State Pollution Control Commission (SPCC), which has the overall responsibility for ensuring that the procedures are applied, need not become involved in administering the procedures and reviewing the EIS. The specific responsibility for doing so in any particular instance is that of the 'determining authority' -the authority which has the primary responsibility for deciding whether the development should proceed. The SPCC may intervene at any time, but does not normally do except where the environmental issues are 'of special significance or highly controversial', or where a public authority other than the determining authority objects to a proposal on environmental grounds. When the SPCC does become involved, however, its decisions are said to be binding on public authorities under the terms of Section 13 of the SPCC Act; this contrast with the Commonwealth requirement that the administering Minister's comments must be 'taken into account' in decision-making.

Dealing briefly with the other States: the Queensland procedures emphasize decentralization of the process of initiation, administration, and assessment of EIA to the particular department responsible for approving the proposed development. Current administrative changes are reinforcing this approach. South Australia has no formal EIA procedures and there have been considerable delays in the introduction of proposed legislation. Tasmania has published EIA procedures. In Victoria the primary emphasis has been on carrying out a programme of comprehensive regional environmental studies. Nevertheless, some important EIA's have been completed and 'guidelines for environment assessment' were published early in 1977.

Until recently, the Western Australian authorities have not favoured formalization of EIA procedures. Their reasons include the view that separate legislative enforcement would isolate environmental aspects rather than integrating them with the overall management process. Environmental impact assessment, however, has been carried out informally by the Environment Protection Authority in conjunction with other departments and developers. The State has now prepared draft administrative arrangements which include a requirement for 'environmental review and management programs' similar to EIA, to be undertaken by the proponents of environmentally detrimental proposals.

A2.2.4 An Overview

EIA has been in operation in Australia for a relatively short time, and the procedures adopted differ amongst the States and Commonwealth. Nevertheless, there are sufficient similarities and emerging trends to enable some generalizations to be made about the characteristics and progress of Australian EIA procedures.

The United States example was a major factor in stimulating the introduction of EIA to Australia. But observation of some of the problems of the early United States experience, together with the influence of a differing political and institutional framework, has resulted in a system which varies considerably from the United States model. In overall terms, there has been less emphasis on quantification and summation of impacts; far less involvement with the Courts; and a slower rate of implementation of EIA.

The less comprehensive approach to the collection of data and the quantification of impacts is to a large extent attributeable to the less demanding requirements of administrative rather than judicial review. But it also reflects a pragmatic realization that the extent of programmes of data collection and analysis needs to be closely related to their likely influence on the decision-making process.

Similarly, after some initial enthusiasm, decreasing use has been made of evaluative techniques designed to aggregate and compare the total impacts of alternative proposals by attributing numerical values to both quantifiable and unquantifiable impacts. It has for the most part been accepted that such evaluations should be left to the political process of review, rather than being subject to the probably unrepresentative judgements of the professionals carrying out the EIA.

The general avoidance of the Courts has been brought about largely by deliberate political choice, and reflects an established preference for resource allocation by administrative rather than judicial processes. This preference is embodied in the discretionary nature of the Commonwealth legislation, and the States have achieved a similar result by avoiding the introduction of specific legislation in support of their EIA procedures.

Reliance on administrative processes has had benefits in avoiding the costs of both litigation and its accompanying project delays, but it has also contributed to a slower and more piecemeal implementation of EIA. Other factors have also helped retard the rate of implementation, including the greater preoccupation of governments in recent years with problems of the economy and unemployment. There has also been considerable reluctance to comply with the EIA requirement amongst many public and private organizations. To some extent this has been an inevitable outcome of bureaucratic politics and self interest, but it has also stemmed from valid criticisms concerning the limitations and problems of EIA.

Given these circumstances, and the reluctance of governments to strengthen their hand, environmental administrators have generally opted for a process of gradual education rather than an attempt to obtain full and rapid compliance with EIA procedures. Consequently the rate of implementation will continue to be slow. There is also a danger in some areas that rather than becoming an accepted part of the planning process, EIA will remain an optional technique to be applied when political expediency dictates.

More positively, however, it is necessary to distinguish between the degree of implementation of formal EIA procedures and the extent to which various elements of environmental assessment are becoming integrated with the planning process in a less formal way. Gradual improvements are being made in the use of environmental expertise, in the consideration of environmental factors, and in the environmental content of planning reports, while at the same time full or formal adherence to EIA procedures is avoided. The EIA must nevertheless receive some credit for having acted as a catalyst for such improvements.

Both directly and indirectly, the introduction of EIA procedures has helped improve the consideration of environmental factors in decision-making and the flow of information to and from the public. But the question remains as to whether EIA, at least in its present form, is the most appropriate means of achieving these ends. The experience to date indicates both the desirability of developing modified procedures more closely integrated with the planning process and the need to avoid excessive reliance on EIA-type procedures by placing increased emphasis on the development of a broader range of strategies for improved environmental management.

Selected Bibliography

Papers

Australian Conservation Foundation (1974) The EIS technique. Papers of an Australian Conservation Foundation symposium held at the Australian Academy pf Science, Canberra, November 1974.

Fisher, D.E. (1977) The federal environment protection procedures. Federal Law Review 8, No. 2, 164-193.

Formby, J.R. (1977) The Environment Impact Statement : problems and alternatives. CRES General Paper JRF/1, delivered to the 48th ANZAAS Congress, Melbourne, September 1977.

Higgs, H. F. and Pryor, R. F. (1976) The Commonwealth's environmental assessment legislation. Paper prepared for the Western Australian Department of Conservation and Environment Assessment Workshop, July 1976.

Linacre, E. (Ed.) (1976) Environmental impact assessment (special issue). Search 7, No.6, June.

Legislation, Procedures

Commonwealth of Australia (1974) Environment Protection (Impact of Proposals) Act 1974.

Commonwealth of Australia (1974-5) Administrative Procedures under the Environment Protection (Impact of Proposals) Act 1974- 75.

Department of the Environment, Tasmania (undated) Guidelines and Procedures for Environmental Impact Studies.

Environment Control Council (1975) Procedural Manual for Environmental Impact Studies in Queensland.

Ministry for Conservation, Victoria (1977) Guidelines for Environment Assessment. State Pollution Control Commission (1974) Principles and Procedures for Environmental Impact Assessment in New South Wales. 

A2.3 CANADA 'S POLICY ON ENVIRONMENTAL ASSESSMENT FOR FEDERAL ACTIVITIES

P. J. Duffyand W. S. Tait, Federal Environmental Assessment and Review Office, Environment Canada, Ottawa, Canada

A2.3.1 The Canadian Federal Environmental Assessment and Review Process 

On December 20, 1973, the Canadian Cabinet decided to establish an Environmental Assessment and Review Process to ensure that:

1. environmental effects are taken into account early in the planning of new federal projects, programmes, and activities; 
2. an environmental assessment is carried out for all projects which may have an adverse effect on the environment before commitments or irrevocable decisions are made; projects with potentially significant environmental effects are submitted to the Department of the Environment for review;
3. the results of these assessments are used in planning, decision-making, and implementation.

Federal projects include those initiated by federal departments and agencies; those for which federal funds are solicited; and those involving federal property. This definition covers projects that may originate outside the federal government but involve a particular federal department through funding or property considerations. In such cases, the federal department sponsoring the project is responsible for the environmental assessment. All federal organizations are bound by the Cabinet decision except proprietary crown corporations and regulatory agencies, which are invited, rather than directed, to participate in the process.

The Cabinet decision also directed the Minister of the Environment to develop, in close cooperation with other ministers, the process and procedures required to accomplish the objectives noted. This was clearly a case of an environmental programme promoted and coordinated by the Department of the Environment but involving all federal departments and agencies in the decisions required for implementation. To fashion a successful federal process, it was recognized that planners, policy-makers, and operators in all federal agencies should give the same consideration to environmental consequences as they do to economic, social, and technical factors in framing and implementing their programmes and projects. The provision of sufficient 'lead time' between the conception of a project and its implementation to permit a proper assessment of environmental concerns and identify suitable requirements for environmental protection and enhancement was another major consideration .

There is now a financial policy on the sharing of environmental assessment costs between the federal government and non-federal government proponents of projects subject to the Environmental Assessment and Review Process. This policy is based on the 'polluter must pay' principle. The federal government accepts the financial responsibility for environmental baseline studies, while the cost of preparing environmental evaluation reports is the responsibility of the proponent. The government and the proponent share the cost of accelerated baseline studies, the incremental cost resulting from acceleration being charged to the proponent.

A2.3.2 The Process Begins

The process now established is based essentially on the self-assessment approach. Departments and agencies are responsible for assessing the environmental consequences of their own projects, or those they sponsor, and deciding on the environmental significance of the anticipated effects. Whether potential adverse effects are considered significant or not depends initially on the judgement of technical and environmental specialists. This judgement takes into account the potential for concern and controversy that a project might create in the public and within professional communities.

As early in the planning phase as possible, a department undertakes to screen projects and activities for which it is responsible to identify potential adverse environmental effects. To help federal departments and agencies, the Department of the Environment has developed screening guidelines designed in matrix form to provide the user with a quick method of identifying the relationships between a broad range of human activities and the environmental elements involved with projects in general.

As a result of this initial screening of a project by the department or agency concerned, one of the following three decisions is possible:

1. There are: (a) no anticipated adverse environmental effects associated with the project; or (b) the anticipated environmental effects are known and are not considered significant.
2. The nature and scope of potential environmental effects cannot be readily determined during preliminary screening.
3. The anticipated adverse environmental effects are considered to be significant and the project requires a formal environmental review by the Department of the Environment.

If decision (1) is made, the department concerned is responsible for implementing measures required to prevent or mitigate the identified environmental effects and satisfying all other legislative, regulatory , and Cabinet requirements related to the development and implementation of the project. However, no further reference to the Environmental Assessment and Review Process is required.

A2.3.3 The Initial Environmental Evaluation (IEE) 

If a department is unable to identify the full environmental consequences and their significance through the screening procedure as indicated in decision (2) above, then the project is subjected to an Initial Environmental Evaluation (IEE). Guidelines prepared by the Department of the Environment covering such project classes as Airports, Nuclear Plants, and Linear Transmission Lines (e.g., pipelines) are available to help federal agencies prepare, or arrange for the preparation of, this document. The IEE provides a description of the project ; of the existing environment and resource use; of potential environmental effects and impacts; of measures proposed to mitigate or prevent certain anticipated environmental effects; and a judgement concerning the impact of those effects that remain after all known measures for prevention and counter-action have been specified. In this description, the alternative ways of accomplishing the project are examined and the preferred alternative(s) identified.

Based on the review of the IEE, the department concerned then decides whether the proposed project involves significant environmental effects or not. If the effects are not considered significant, the department is responsible for implementing appropriate measures for environmental protection that have been specified, but no further reference to the process is required, as in screening decision (I) above. However, if the anticipated effects are judged to be significant, the department then submits the project to the Department of the Environment for a formal review, as in screening decision (3).

Departments and agencies are encouraged to seek environmental advice from the partment of the Environment during the screening procedure and in the development and review of IEEs. The Department has established five Regional Screening and Coordinating Committees across Canada to facilitate this advisory service. Advice from specialists in other departments such as Health and Welfare (health aspects), Energy , Mines and Resources (energy conservation), and Agriculture (pesticides) is also available on request. In addition, consultants outside the federal government could be used for this purpose. Known public concerns about specific projects constitute another important input to departments in making their environmental decisions.

In summary , the prime concern during the screening and IEE phase of the process for project alternatives under consideration is to:

1. specify preventive and mitigating measures for anticipated environmental effects that have been identified and are amenable to such measures. These measures would be incorporated when a project is implemented;
2. identify anticipated effects which are 'left over' after all known remedial measures have been specified and which may have significant impacts on the environment.

If the department involved considers these residual effects to be significant, it then requests the Federal Environmental Assessment Review Office to proceed with a formal review of the project by an Environmental Assessment Panel.

A2.3.4 The Environmental Assessment Panel

An Environmental Assessment Panel is a small body of experts (usually four to six) formed to review the environmental consequences of a specific project and its alternatives and to evaluate the significance of the environmental impacts that might result from implementing the project.

A Federal Environmental Assessment Review Office, under an Executive Chairman, has been established in Environment Canada to administer the process, particularly the operation of panels. The Executive Chairman (or his delegate) chairs all panels formed to review projects, and reports to the Minister of the Environment on the recommendations made by panels. A project submitted for panel review may not be carried out until a decision has been reached on panel recommendations.

A separate panel is established for each project reviewed. Panel members are chosen for their special knowledge and experience relevant to the technical and environmental factors associated with the proposed project. The process also provides for the establishment of an Environmental Review Board by the Minister of the Environment composed entirely of members outside the federal public service. Projects considered special cases because of wide public interest are candidates for the Review Board. The decision to use this procedure rests with the Minister of the Environment and the Minister of the Department involved with the project under consideration.

The Executive Chairman may appoint panel members from within the entire federal public service. The Minister of the Environment may also appoint panel members from outside the federal public service. These appointments will be made with the agreement of the department initiating a project. Previously only persons from the Department of the Environment could be appointed, together with one representative from the federal department or agency whose project was under review.

A 2.3.5 The Environmental Impact Statement

When the Environmental Assessment Panel is formed to assess a project, one of its first tasks is to develop specific guidelines for the preparation of an Environmental Impact Statement (EIS). The EIS is a detailed documented assessment of the environmental consequences associated with the project, and is prepared, or procured through consultants, by the department responsible for the project. It must be prepared in accordance with the guidelines issued by the Panel. The nature of the project and its proposed location will determine in many respects the type of detailed information required. The impact on people due to noise and land use would be prime considerations when assessing a proposal for a new airport. The potential for damage from radiation would be an important factor when a proposed nuclear power generating station is under review.

A 2.3.6 The Process and the Public 

After receiving the Environmental Impact Statement, the panel's next step is to obtain public reaction. Both the guidelines issued by the panel and the Environmental Impact Statement prepared by the federal agency initiating or sponsoring the project are made available to those interested before any formal meetings for public discussion are held. After this information has been issued, the panel arranges to meet the public and receive briefs (oral and written) from individuals and groups who wish to present their viewpoints. Generally, these meetings will be held in the area proposed for the location of the project.

The federal assessment process attaches great importance to anticipated public concerns in determining the 'significance' of potential adverse environmental effects. A panel established to make such judgements, however, must also weigh the scientific and technical evidence in arriving at its conclusions.

Federal departments and agencies are now required to ensure that information is provided to the public and that public response is obtained during the early planning stages of significant projects. Although the existing policy of public participation in the activities of Environmental Assessment Panels will still apply, this initiative will help to create awareness of these projects at an earlier phase in the process.

A 2.3.7 The Decision

When a panel has reviewed the Environmental  Impact Statement, the public response, and any other information it feels is required, it prepares a report for the Minister of the Environment. This report contains the history of events associated with the project, a detailed examination of the vital environmental  factors involved including their major impacts on the social and economic sectors, and recommendations concerning project implementation. A panel could recommend that a project be halted, that it proceed as planned, or that it proceed with certain qualifying conditions and terms. These might include environmental  requirements for project design and the development of certain studies to obtain needed information. They might also include requirements for surveillance during construction and operation of the project to evaluate the performance of environmental  protection measures used, and monitoring the actual environmental  impacts for comparison with predicted impacts.

The panel report is then submitted to the Minister of the Environment through the Chairman, and the Minister must decide whether to accept the recommendations or not. This decision is made in consultation with the minister of the department initiating the project. If they agree to accept the recommendations, the report is released to the public and the initiating department is instructed to implement the recommendations. This ministerial decision would also identify the federal agencies responsible for any surveillance and monitoring needed .

There is the possibility of disagreement between the two ministers on the course of action that should be taken. In this case the matter would probably be referred to Cabinet for resolution. As a general rule, the report to the Minister of the Environment is released to the public regardless of the circumstances.

Some proposed federal projects, such as airports, may have important environmental implications for provincial levels of government. In such circumstances a joint approach to environmental  assessment by the federal and provincial agencies concerned is encouraged under federal assessment policy. Where a panel is formed to review a federal project of this kind, the provincial government involved is invited to contribute towards the specific guidelines developed by the panel for the preparation of the environmental  Impact Statement. Each level of government enjoys the right to review the EIS produced, and to act on the basis of its own conclusions about its adequacy. In this way the duplication associated with two sets of guidelines and two impact statements that might result if each government acted in isolation is avoided. Should there be federal/provincial disagreement in such cases, the action eventually taken would depend on the particular circumstances involved, including the margin of agreement available for compromise.

Departments and agencies in the federal government are still grappling with the complexities related to environmental  affairs in general and the Environmental Assessment and Review Process in particular. It is too soon to judge the performance of this procedure for environmental assessment but an evaluation will be made during the next three years. The initiating departments and agencies are required to provide to the Executive Chairman of the Federal Environmental Assessment Review Office, on behalf of the Minister of the Environment, the relevant information on projects they assess themselves, so as to permit a more comprehensive evaluation of the effectiveness of the Environmental Assessment Review Process. The federal approach spreads the responsibility for decisions concerning the environment amongst departments and agencies to foster sound environmental planning at the source of activities, and involves the public in reaching the decisions that are made to ensure environmental protection. It is an approach that is not prescribed by law but underwritten by a commitment from federal ministers through a Cabinet decision. The degree to which all participants in the process accept their responsibilities, and the quality of the decisions that result, will determine whether the objectives set for the Environmental Assessment and Review Process are achieved.

References

Hurtubise, F. G. (Ed.) (1977a) A Guide to the Federal Environmental Assessment and Review Process. Env. Assess. Panel, Environment Canada, Ottawa. 17 pp.

Hurtubise, F. G. (Ed.) (1977b) Register of Panel Projects No. 1.Env. Assess. Panel, Environment Canada, Ottawa. 38 pp.

A 2.4 THE ENVIRONMENTAL ASSESSMENT SYSTEM IN JAPAN 

Y. Shimazu, Nagoya University, Nagoya, Japan 

The government of Japan has tried to reduce the impact of new development in two ways:

1. by locating polluting activities in areas where harm to the environment would be least, by means of regional planning (positive control); 
2. by preventing the siting of pollution activities in areas where harm to the environment would be unacceptable, by means of EIAs (negative control). 

Concerning the positive approach, a Comprehensive National Land Development Plan was enacted as early as the 1950s. However, Japan was forced to slow down its economic growth rate after the oil crisis, and a revision of the plan was required. The revision was also required because of a rise in environmental concern by the public.

Negative administrative controls, i.e., EIAs, are gradually being introduced. In 1972, a Cabinet resolution on 'counter-measures for environmental preservation with regard to public works' was issued. In 1974, an office of EIA was created within the Environment Agency. EIA is carried out by the prefectural authorities or by the competent ministry (Transportation, Construction, Industry, etc.) under guidelines prepared by the Federal Environment Agency. This procedure was an extension of pollution control laws established as early as 1965. Therefore attention was centred mainly on air and water quality, while the assessment of social impacts was ignored. The feedback of the inhabitants' opinions into project planning was also insufficient.

In 1976 and 1977, the Environment Agency proposed an EIA Act to the Diet but no legislative action was taken. Instead, EIA Acts are now being passed at the prefectural and municipal levels. As an example, the legislative procedure established at Kawasaki City (population one million) is shown in Figure A2.1. This procedure is applied to both public and private works, and the minimum size of project to be reviewed is specified (e.g., 1 ha for an industrial plant and a housing park). Before the procedure was implemented, a Regional Environmental Management Plan (REMP) was established, by which an individual project is screened at the first stage of a proposal. Environmental monitoring after a project has begun is another significant feature of the system. The mayor can decide whether 'to go' or 'to no-go' by consulting with an advisory committee whose members are specialists in the environmental sciences and law. The proponent-pay principle has been adopted. Naturally the social and cultural environments are assessed.

Significant environmental degradation in Japan is due to the severe pressures on land use; establishment of Regional Environmental Management Plans (REMPs) giving guidelines for land use was therefore crucial. Several prefectural and municipal authorities have established environmental assimilative capacities, in which maximum permissible outputs of effluents to the air and water are designated for respective land-use zones and watersheds. An index of the degree of wilderness has also been developed, the values being determined from ecological information, and the desirable index to be maintained is defined for individual categories of land use patterns. 

To support REMPs and EIAs, an environmental information system or data base is also being developed, a schematic of which is shown in Figure A2.2 Data for 1 km x 1 km grid size are obtained for population structure, land-use patterns, watershed patterns, surface geology and soils, vegetation, industrial activities, transportation patterns, pollution levels, natural and cultural properties, inhabitants' rights, etc. The environmental information is open to the public.

Because of the large numbers of very local construction projects, development of a methodology of EIA which can be applied to rather small-scale projects (100 ha) was urgently required. A new comprehensive and interdisciplinary system has been established with some success. Its characteristics are as follows:

1. The system covers the whole process from the planning stage, through construction, to completion. 
2. Assessment of both the social environment (safety and amenity of communities, cost/benefit for individuals and the public including employment, income, population density, consumption, land-use pattern, industrial structure, finance, and public service, etc.) and the natural environment (quality and quantity of natural features, pollution, disaster) is considered. The daily practices of the inhabitants should be essential environmental quality indicators; these are determined through field surveys. 
3. One difficulty is due to a lack of consensus in the views of the municipality, of the enterprise and of the inhabitants. Therefore a coordination system is included and a liaison committee on environmental preservation has been established with members from the administrative offices, from the enterprise, and from the inhabitants, in which the assessor acts as chairman.
4.  Utilization of a simulation model should be considered for an objective assessment. However, some of the impacts cannot be predicted with confidence, especially those related to ecosystem behaviour. Therefore, a continuing monitoring system is included to provide early warning of impacts, permit ting counter-measures to be taken. This feedback system will also be helpful to prevent accidents. 
5. Under the direction of the committee described in (3), an environmental management centre is established to monitor the natural environment and to coordinate studies on the social environment (guidance, information feedback). The staff of the centre has an office at the developmental site during the whole process. 
6. The assessment statement is made available to the public, special attention being given to the form of presentation and the means of information feedback. A newsletter is circulated regularly, edited by the assessor. 
7.  An interdisciplinary approach is necessary , but the organization of an interdisciplinary project team is difficult because of the large numbers of developmental projects and the cost limitation. In the present system, a small group of assessors (one is enough in most cases) is sufficient; this is called the 'all-round player' system. A detailed manual has been prepared (Shimazu, 1977a) and a training system has been established. The technique of daily patrols of the area is similar to the so-called boy-scout approach.  

This system could be applied in developing countries where the number of specialists is limited.

For additional information, see OECD (1977); Shimazu (1977b); Shimazu and Harashima (1977).

References

OECD ( 1977) Environmental policies in Japan. Report by the OECD Secretariat, OECD, Paris, France. 93 pp.

Shimazu, Y. (1977a) Environmental impact assessment. NHK Books. 251 pp. (in Japanese ).

Shimazu, Y. (1977b) Environmental assessment and management system in Japan. Int. Federation on Automatic Control, Env. Systems Symp., Kyoto, p. 43.

Shimazu, Y. and Harashima, R. (1977) Environmental assessment-management system for local developmental project: cases in Japan. J. Envir. Management, 243-258

A 2.5 IMPACT ANALYSIS IN UK PLANNING*

B. D. Clark, K. Chapman, R. Bisset, K. W. Pearce and P. Wathern, Project Appraisal for Development Control, Department of Geography, The University, Aberdeen, Scotland

*The views expressed are those of the study team and should not be taken as a statement of the views of the sponsors, the Department of the Environment or the Scottish Development Department.

A 2.5.1 Introduction

Within the last 10 to 15 years, increasing concern has been expressed in the UK about the effects of new development on the quality of the environment and the ability of the planning system to take the effects into account. Encroachment on the countryside by new and expanded towns, motorways, and industry has been a significant factor in increasing public anxiety regarding the implications of development for the environment. The concern is not new, but until recently the proposals which have aroused opposition have been intermittent and geographically dispersed. About 1970, however, the situation changed. For example, the onshore requirements for the exploitation of North Sea oil and gas resulted in the concentration of many unfamiliar and controversial proposals within a few areas. Another important characteristic of oil-related activities has been the large number of applications which represented a potential incursion of industry into rural areas with long-established small communities lacking an industrial tradition. Consequently, concern about such proposals has encompassed not only impacts on the physical environment, but also social and economic issues. This has had the important effect of focusing attention on the inherent difficulties of ensuring adequate examination and analysis of complex proposals without undue delay in reaching a decision.

A 2.5.2 Existing Procedures

There is a wide range of procedures in the UK to control the detrimental effects of proposed development. These procedures can be classified into two groups, planning controls and pollution controls.

A 2.5.3 Planning Controls

The authorization of major development proposals in the private sector is regulated by Part III of the Town and Country Planning Act 1971 (as amended) in England and Wales and by Part III of the Town and Country Planning (Scotland) Act 1972 (as amended) in Scotland. An application for development must be made to the appropriate local planning authority. A decision to grant or refuse planning permission is made by the authority after the implications of the proposed development have been assessed. This decision should be made within eight weeks (two calendar months in Scotland). Applications for, proposals which raise particularly significant issues may be 'called in' by the appropriate Secretary of State (the Secretaries of State for Environment, Scotland and Wales) for determination by central government. An applicant who has been refused permission by a local planning authority may appeal and have his application reconsidered by the Secretary of State. When important issues are raised by planning applications or by appeals, a public inquiry may be held under the direction of a person appointed by the Secretary of State to ascertain the facts relating to the application. Anyone with an interest in or evidence about the proposals may appear at an inquiry .The final decision to grant or refuse planning permission is made by the Secretary of State.

Development in the public sector follows a broadly similar set of procedures. For example, development by a central government department is normally undertaken only after exhaustive, but non-statutory , consultations with local authorities and other departments likely to be affected by the proposals. Major developments by statutory undertakers, such as the construction of a power station, are normally subject to a separate authorization procedure operated by the appropriate government department (in this case the Department of Energy). This authorization is deemed to include the granting of planning permission. Frequently, public local inquiries are held before such decisions are made. The third main type of development in the public sector is by local authorities. Such development is deemed to have planning permission subject to compliance with regulations made under the Acts.

A 2.5.4 Pollution Controls

Much of the control of adverse effects of proposed development is regulated by statutory bodies not covered by the planning legislation. The most important pollution legislation relates to the control of air pollution, water pollution, solid waste disposal, and noise.

Certain developments, called registrable works, have been identified as potential sources of high air pollution levels. Such works are controlled by the Alkali and Clean Air Inspectorate in England and Wales under the Alkali, etc., Works Regulations Act 1906 (and subsequent regulations) and in Scotland by the Industrial Pollution Inspectorate under the Alkali, etc., Works Regulations (Scotland) Act 1906 (and subsequent regulations). Prior approval of the Inspectorate is required before a new plant can be operated. Pre-defined standards of air quality are not used to regulate emissions; each plant is considered on its merits and pollution is controlled by 'best practicable means', such as the installation of pollution control equipment or the construction of tall stacks to disperse pollutants. The regulation of emissions from other non-registrable works is controlled by local authorities.

Consent must be obtained from the Regional Water Authority (River Purification Board in Scotland) in order to discharge liquid effluent to a water body. These consents can be issued subject to conditions such as the concentration of total volume of effluent to be discharged.

Local authorities are responsible for the control of solid waste disposal under.. Part I of the Control of Pollution Act 1974 and under the Deposit of Poisonous Waste Act 1972. Sites for the disposal of household, commercial, and industrial waste must be licensed by the appropriate waste disposal authority. These licences can only be issued after consultation with the Water Authority or River Purification Board to ensure that water resources are not polluted. The disposal of radioactive waste from licensed sites in England and Wales is the responsibility of the Department of the Environment and the Ministry of Agriculture, Fisheries and Food. In Scotland, this is the responsibility of the Industrial Pollution Inspectorate.

The control of noise nuisance is the responsibility of local authorities under Part III of the Control of Pollution Act 1974. This gives control over fixed noise sources such as construction sites and certain premises in designated noise abatement zones.

A 2.5.5 Impact Assessment

It is unlikely that new legislation will be implemented in the UK, formally requiring EIAs. The existing legislation and procedures will probably be adapted to lake account of advances in impact analysis, so that environmental, social, and econornic aspects of development proposals can be given closer scrutiny during appraisal. There have been two main recent developments in the field of impact appraisal. First, the impacts of specific developments have been assessed. Secondly, research has been conducted on the role of impact analysis in the UK and on the development of suitable methods for assessment within existing UK planning practice.

Impact studies have been commissioned in response to the influx of planning applications for oil-related developments, particularly in the sparsely populated regions of Scotland. The Scottish Development Department, in collaboration with the respective planning authorities, commissioned studies on the Loch Broom and Loch Carron oil-production platform fabrication yards. An assessment of the environmental impacts of a proposed gas-liquids plant was also commissioned. Developers have also employed consultants to produce reports in support of applications. For example, impact statements have been prepared for the Flotta oil terminal, Orkney, the Sullom Voe terminal in Shetland, and for development of the Beatrice on field in the Moray Firth. Most of these reports have been used to assess planning applications, although the Beatrice study was submitted to the Department of Energy in support of a licence application to develop the field .

The research commissioned on the role of impact analysis in UK planning has been equally significant. A general review of how EIA procedures might be incorporated within the existing machinery was carried out by consultants appointed by the Department of the Environment (Catlow and Thirlwall, 1976). They concluded that detaned EIAs could usefully be required for the 20-50 major proposals considered each year , and suggested criteria that might be used in deciding whether a development, because of its nature, scale or location, fell into this class. The question of how to assess the likely impact of a development was considered in another study by the Project Appraisal for Development Control research team at Aberdeen University , commissioned in 1973 by the Scottish Development Department and the Department of the Environment to produce a manual for local planning authorities and so assist them in making a balanced assessment of major industrial planning applications taking social, economic, and environmental effects into account.

The work was based upon an assessment of best UK planning authority practice in assessing proposals, US experience of implementing the National Environmental Policy Act, information on the impact of major industrial plants, and a review of the assessment procedures used in the appraisal of more than 50 major industrial developments. The resulting manual (P ADC, 1976) has four objectives:

1. to provide an overall method for appraising applications;
2. to ensure that adequate information is provided by a developer so that an application can be assessed;
3. to provide a means whereby impacts can be identified in a systematic way;
4. to provide information and advice to local planning authorities on certain types of potential impact.

The manual contains a proposed method and several appendices. The proposed method is shown in Figure A2.3. It is not a rigid sequence of stages, but a series of linked activities some of which may be concurrent.

Figure A 2.3 The structure of the United Kingdom approach to environmental appraisal (PADC, 1976)

During the study it became apparent that failure of the developer to provide information on the plant and its processes early in appraisal was one reason for delay in processing applications. An outline for a Project Specification Report which provides a framework for the assembly of this information is included in the manual. For major developments, it is suggested that a Project Specification Report should be submitted with a planning application. Although full design specifications of a plant may not be available at the time of application, the brief should advise applicants of the detailed information which should be supplied to the authority at the earliest opportunity. The brief is not designed to be universally applicable, as certain sections may not be relevant to specific developments. It is intended that it should serve as a base to be modified by a planning authority.

There are a number of subject areas, such as ecology, noise, and landscape character, which should be considered during appraisal. Technical advice notes concerned with 10 different types of potential impacts are included in the manual. When local authorities do not have expertise in a particular field and decide to employ consultants, these notes should aid the design of contract briefs and the interpretation of consultants' reports.

The method proposed in the manual can be operated under existing legislation. It is designed to be used by local planning authorities for the assessment of major industrial developments, but could also be used for the assessment of other types of private development. The manual could also be used by local authorities to ascertain the local impacts of public sector development prior to consultation with the statutory body responsible for development. It is currently being tested in cooperation with a number of local authorities and other agencies; any future revision or modification will be influenced by their experience. The Department of the Environment, the Welsh Office, and the Scottish Development Department also commissioned a review of procedures for introducing environmental impact analysis into the UK. A report has been published as DOE Research Report No. 11 entitled Environmental Impact Analysis. In this report it is concluded that there is a need to employ a flexible system of impact analysis in the UK for certain major projects. A number of different development types are identified which might be candidates for impact analysis. However, no standard requirements are recommended in this study and it is suggested that impact analysis should be integrated into the existing planning framework.

It is difficult to introduce mandatory requirements or pre-defined categories of projects for impact analysis, as ultimately the sensitivity of the environment will determine the major developments. A flexible approach should ensure that a detailed appraisal is undertaken for those projects which require an EIA.

A2.5.6 Conclusion

EIA procedures in the UK are still being developed , and are not formalized as in some other countries. The impact of proposed development is considered, but not in a standard way. Steps towards grafting more formal procedures on to existing planning controls have been advocated in recent reports- especially for large or potentially hazardous developments in sensitive areas. Such proposals imply creation of a capacity to screen development applications, and the existence of an adequate environmental data base. Catlow and Thirlwall (1976) recommend that impact analysis could be directed by a steering committee appointed for each development. Both developers and local authorities would participate in the appointment of the steering committee. Other proposals have been advanced (PADC, 1976) in which a local planning authority would have sole responsibility for carrying out impact assessment. Local authorities might still review smaller schemes and central government large ones. These ideas are still being debated, and for the foreseeable future the form and detail of EIA in any particular case seems likely to depend on the judgement of the local planning authority or of central government, depending on which considers the application.

References

Catlow, J. and Thirlwall, C. G. (1976) Environmental Impact Analysis. Research Rep. No. 11. Department of the Environment, UK. 116 pp.

PADC (1976) Assessment of Major Industrial Applications: a Manual. Research Rep. No. 13. Dept. of the Environment, UK. 170 pp.

PATARC (1975) Symposium on Environmental evaluation. Dept. of the Environment, UK. 250pp.

Wathern, P. (1976) The role of impact statements in environmental planning in Britain. Int. J: Env. Studies 9, 165-168.

A 2.6 THE EIA PROCEDURES IN THE UNITED STATES*

A 2.6.1 The National Environmental Policy Act

The EIA procedures in the United States were established and are carried out under the National Environmental Policy Act enacted on January 1, 1970. There are three main parts to the Act. First, there is a declaration of national policy and with it a prescription of environmental goals which the Federal Government is to pursue; second, the Act specifies that Federal agencies are to prepare environmental impact statements on those Federal actions significantly affecting the quality of the human environment; third, the Act provides for environmental concerns to be institutionalized in the Executive Office of the President through the establishment of the Council on Environmental Quality (CEQ).

The main thrust of the Act is to ensure that environmental concerns receive adequate attention at all levels of governmental planning, decision-making, and action. The stated purposes are as follows:

'Section 2. The purposes of this Act are: to declare a national policy which will encourage productive and enjoyable harmony between man and his environment: to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man: to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality.'

*Edited by Peter L. Cook, Acting Director, Office of Federal Activities, EPA, Washington, D.C., and based on the corresponding sub-section appearing in the first edition of SCOPE 5

A 2.6.2 The Environmental Impact Statement

The Act requires that all Federal agencies, to the maximum extent possible, prepare an Environmental Impact Statement (EIS) prior to taking any major action or reporting on legislation that would significantly affect the environment. The basic purpose is to force the Federal agencies to comply with the policy presented in the Act.

The process, which is intended to serve as a decision-maker's tool, has three broad functions. First, it is an action-forcing mechanism, aimed at ensuring that an environmental  analysis or assessment is performed at the outset and that the result of the analysis becomes part of the decision-making process. Second, through its evaluation of impacts and required consideration of alternatives, it should serve as an option-defining instrument. Third, it serves to furnish a detailed record of environmental decision-making for purposes of review by Federal, state, and local agencies, by the Congress, the President, the Courts, and the public.

The Council on Environmental Quality, among its various duties, is charged with maintaining an overview of the operation of the Environmental Impact Statement process, and with providing guidance to ensure that it effectively accomplishes its purpose. The Council periodically publishes procedural guidelines, and requires that each Federal agency publish its own guidelines in response. There is provision for revision of the guidelines at appropriate periods, in the light of experience with the system's operation.

It is the responsibility of the proposing agency to prepare the Environmental Impact Statement. Where an action involves several agencies, the one with the primary responsibility for the action is designated 'lead agency' , but all agencies involved have a role in the preparation of the statement. In cases where the action is proposed by, or is to be carried out by, a non-governmental entity (as in the case of a power plant licensed by government to be constructed by a private firm), the governmental agency responsible for the Federal connection with the action (in this case, issuing the licence) has responsibility for the statement.

The process is applicable to all types of Federal actions, including physical construction projects, administrative actions, and proposals on legislation. Because Federal actions include licensing, permitting, or funding a wide variety of state, local, and private actions, the process is applicable to many kinds of activities in the United States.

As required by regulations, the Environmental Impact Statement must contain the following:

1. Description of proposed action; statement of purposes; description of  environment affected;
2. Relationship to land-use plans, policies, and controls for affected area; 
3. Probable impact-positive and negative; secondary or indirect, as well as primary and direct; international environmental implications;
4. Consideration of alternatives;
5. Probable adverse effects which cannot be avoided;
6. Relationship between local and short-term uses and long-term environmental considerations;
7.  Irreversible and irretrievable commitment of resources;
8. Description of what other Federal considerations offset adverse environmental effects of proposed action and relation of these to alternatives.

In addition, the comments received from reviewers must be attached.

A 2.6.3 Operational Procedures

The procedures adopted in the United States and the parties involved are shown in Figure A2.4. The guidelines call for all agencies of the Federal Government to utilize a systematic, interdisciplinary approach which will ensure the integrated use of the natural and social sciences and the environmental design arts in planning and decision-making which may have an impact on man's environment.

Figure A 2.4 Schematic of the United States Environmental Impact Assessment procedure. Open triangles represent decision nodes. EIS, Environmental Impact Statement; CEQ, Council on Environmental Quality

1. The proponent agency develops a proposal for action. The agency must determine if the action will significantly affect the quality of the human environment. If so, it is responsible for preparation of the Environmental Impact Statement.

2. If an Environmental Impact Statement is required, the proponent may consult with the Council on Environmental Quality, the Environmental Protection Agency (EPA) and other Federal agencies with special or unique expertise, state and local agencies in cases where projects might affect them, and the public in open hearings if needed, to develop material for the draft Environmental Impact Statement. The draft EIS is then filed with EPA.

3. The draft must be reproduced and simultaneously circulated to the Council an Environmental Quality, EPA, Federal expert agencies, state and local agencies, and the public for review and comment.

4. After this review process (from 45 to 60 days), a final Environmental Impact Statement is filed by the proponent with EPA and distributed to all of the above agencies and the public.

5. The final statement, which includes the comments of all of the reviewers, is submitted to the decision-maker, who could be an agency head or secretary .

6. The decision-maker reaches a decision. Where the proposed project requires legislation, the Environmental  Impact Statement will be submitted to Congress and the President for consideration in taking final action.

7. Initiation of the proposed action is begun only after all steps have been completed. In this connection, it is important to note that a citizen's suit may be brought to the Courts.

The guidelines for EIA in the United States are reviewed from time to time to take account of experience in operating NEPA and recent advances in EIA methodology .

A 2.7 ENVIRONMENTAL IMPACT ASSESSMENT PROCEDURES IN EAST EUROPE

In East European countries the central planning system provides a coherent framework for EIAs. The current national perspective plans covering the period up to 1990 contain sets of goals for environmental quality; to make them operational, attempts are being made to establish links between economic and territorial planning so as to permit the possible impact of planned projects and activities on specific environments to be considered; research on related methodologies is in progress. The annual and medium-term plans which are operational and legally established include dermite targets for a certain range of environmental impacts.

In the framework of the Council for Mutual Economic Assistance (CMEA)*, a set of principles for EIA has been worked out. The basic goals of the methodology are: (1) giving maximum satisfaction to the demands of society; (2) restoration and improvement of the environment; and (3) satisfying (1) and (2) at minimum costs. The approach is a regional one and the tools used for assessing the impacts of human activities are derived from complex geographical analysis. Extensive use is made of inventories of natural resources and socio-economic conditions and of the automation of mapping processes. The whole procedure of EIA is viewed as part of a systems analysis, using information theory, modelling, and computer techniques.

*CMEA is an economic organization of socialist countries (Bulgaria, Cuba, Czechoslovakia, GDR, Hungary , Mongolia, Poland, Romania, and USSR).

The methodology developed by the CMEA member countries  includes several phases: (1) the choice of basic elements of the environment, of the types of man's activities affecting the environment, and of the types of assessment required. The assessment may be technological, bio-medical, economic, or social, the latter being the most comprehensive and including, in fact, all the other types of assessment; (2) the elaboration of a general system, based on a set of matrices including: the natural environment, the man-made environment and socio-economic activities; a global matrix, showing the interactions between the different sub-systems built up (the model constitutes an open system and has a probabilistic character); (3) complex geographical analysis, defining the natural resources and conditions (e.g., landscape and geological structure, soil, vegetation, fauna, etc.), each being considered under various aspects such as anthropogenic changes, conflicts in connection with man's activities, maximum allowable load (ecological aspects), etc. (a similar study is made of the socio-economic factors of development plans); (4) cartographical analysis, which is an important stage in the overall methodology; scientifically developed maps are used as forecasting models of the process of development and of the assessment of man's impact; (5) cost-benefit analysis, intended to examine the relations between the costs of using elements of the environment and the beneficial output which these elements provide; it is recommended that a system of indicators should be established for this purpose, but at present this problem has not yet been solved.

In addition to the general approach just described, some other specific techniques are used in the CMEA member countries. Mention should be made of checklists, which present a classification of environmental components (atmosphere, biosphere, soils, phytosphere, etc.) and allow the analyst to report negative and positive impacts of human activities on these elements.

Acknowledgement

This material is reprinted with permission from an ECE document Environmental Impact Assessment, ENV /R.53 , 23 Dec., 1976, UN Economic and Social Commission, Economic Commission for Europe, Geneva, Switzerland.

A 2.8 PROCEDURES USED BY THE WORLD BANK*

A 2.8.1 The World Bank

The World Bank is a group of three institutions, the International Bank for Reconstruction and Development (IBRD), the International Development Association (IDA), and the International Finance Corporation (IFC). The common objective of these institutions is to help raise standards of living in developing countries by channelling financial resources from developed countries to the developing world.

*Based on a preprint written by Dr. J. A. Lee of the World Bank presented in New York, October 14, 1976, at an international briefing sponsored by the Center for International Environmental Information.

The Bank has committed itself to helping its 127 member countries with their many intractable development problems, including, among others, questions of income distribution, rural and urban poverty, unemployment, excessive population growth, rapid urbanization and, of late, environmental protection and rehabilita lion, and preventive medicine and health care delivery .

A 2.8.2 Environmental Considerations in Development Assistance

The environmental problems of the developing countries can be divided into two categories: effects of poverty and effects of economic development.

Under conditions of poverty, the biophysical environment often exhibits the ravages of long years of mismanagement (over-gazing, erosion, denuded forests, surface water pollution, etc.). Not merely the 'quality' of life but life itself is endangered, for it is often very difficult and sometimes impossible for the environment to renew its life-supporting capabilities. Developing countries assign the highest priority to finding solutions to problems of this nature. Here the principal concern is to rehabilitate the environment that has gone through a long period of deterioration.

The other set of problems accompanies the process of development itself. Agricultural growth, for example, calls for construction of irrigation and drainage systems, clearing of forests, use of fertilizers and pesticides -all of which have environmental  and health implications. Similarly, the process of industrialization could well result in the release of pollutants and in other environmental problems related to the extraction and processing of raw materials.

In sum, developing countries are now beginning to be concerned with two different types of environmental problems. In the first type, these nations have to alleviate poverty; while in the other, they have to seek ways to prevent the environmental deterioration often associated with development. The first task is considerably more difficult than the second, but the second could also become difficult if the present concern for the environment is not translated into action. The Bank is concerned with both aspects of the problem.

A 2.8.3 The World Bank's Approach

Though the World Bank prior to 1971 had concerned itself with the environmental implications of its development activities, no systematic procedure existed to identify and examine those effects. More importantly, methods to prevent or mitigate adverse consequences had not, in many instances, been devised. In late 1970, however, the post of Environmental Adviser was established and given a strong mandate to review and evaluate every investment project from the standpoint of its potential effects on the environment. That post has now grown into an Office of Environmental and Health Affairs which oversees the Bank's environmental activities, including, especially, ensuring that projects proposed for financing are examined for their ecological, health, and socio-cultural effects and that appropriate measures are taken to prevent or mitigate serious adverse consequences.

Important to this task bas been the Bank's handbook Environmental, Health, and Human Ecological Considerations in Economic Development Projects. Prepared for use by the Bank's own staff, the handbook has found widespread use through. out the developing world, including government planners, borrowing entities, engineering and construction firms, consultant organizations, universities, etc. As environmental considerations have more and more become a fixed part of Bank operations, these guidelines and criteria now cover many different kinds of project possibilities and settings and are used in the evaluation of environmental impacts of virtually all projects. An example of a set of guidelines (for power plants) is given below in Section A2.8.4 (World Bank, 1974).

Experience in environmental evaluations within the Bank has given rise to a series of operations which are now being followed for each project believed to have significant environmental/health/human ecological impacts.

In brief, these include :

1. In-house study of the proposed project, utilizing the Bank's technical staff.
2. On-site 'environmental reconnaissance' to determine likely impact of the project; the problems, if any, likely to result; recommendations for preventing or mitigating such problems; or recommendations for in depth studies of particular environmental responses.
3. In-depth studies are the subject of multidisciplinary investigations conducted under terms of reference carefully tailored to the conditions and requirements surrounding the particular project, or component thereof.
4. Projects of such a nature that their environmental impacts are of unique importance to a regional or global audience, and wherein singularly unique and important environmental values are involved, must, of necessity , be the object of comprehensive and detailed studies to determine how or if the project can proceed.
5. Projects for which environmental safeguards or controls are to be included are examined during the construction and pre-operation stages to determine their adequacy and sufficiency in light of any changes which may have occurred subsequent to final appraisal.
6. Projects in operation are examined periodically to determine the continuing adequacy of environmental safeguards and the need, if any, for new or improved controls.
7. Projects involving 'important ecological systems' are subjected to 'environmental post-audits' at appropriate points in their implementation to determine the accuracy of the pre-project impact assessment and the actual consequences for such systems.

In each and every project subjected to one or more of the steps cited above, the environmental safeguards which may be indicated are the object of cost/benefit analysis. Efforts are continuing to develop a more suitable methodology for identifying the diseconomies, social and opportunity costs, and benefits to be anticipated. The difficulties experienced in this regard are many, and are the subject of increased research.

The environmental studies seen as being requisite to financing a project are, in most instances, financed by the borrowing entity , in much the same manner as other aspects of project preparation, such as engineering, geology, marketing, etc. In some cases involving poor countries, the Bank may finance the required studies. Increasingly, the borrowing entity is encouraged to make the necessary studies, while the Bank reserves the right to approve the terms of reference and the qualifications of those employed in their conduct. The Bank does assist, where appropriate, in preparing the terms of reference and in defining the disciplines to be used in the studies. In some instances, the Bank will conduct the required studies being financed by the borrower. In any event, findings of environmental studies are shared jointly with the borrower, member country government, and the Bank.

Thus, while no format 'impact statement' on the environmental consequences of a development project is strictly required, the Bank does require that major adverse effects be avoided or mitigated and, as indicated, has established systematic procedures for accomplishing this. To date, all projects requiring safeguard measures have been successfully negotiated with the borrower and member country.

Industrial projects are of especial concern to the Bank-in FY 1976 the Bank and IFC loaned over $800 million in that sector. Like projects in the other sectors, industrial projects are examined for their environmental, occupational health, and worker safety aspects.

In addition to the extensive guidelines provided in the Bank's handbook, more specific and detailed effluent and emission guidelines have been prepared for the many types of industries financed by the Bank (World Bank, 1977). There are close working relationships with the WHO, UNIDO, ILO, ECE, and others active in the industrial field.

A2.8.4 An Example of a Set of Environmental Guidelines (World Bank, 1974, pp. 38-40)

POWER PLANTS (FOSSIL-FUELED, NUCLEAR-FUELED AND HYDRO- ELECTRIC)

A. Environmental/Resource Linkages

• What site selection criteria will be used?
• Will they include environmental considerations, such as effects on air and water quality, and the resulting impact on residents of the area, fish, wildlife, and vegetation?
• Will alternative sites and alternative orientation of the plant be considered in order to minimize adverse environmental impacts?
• Does the site correspond to other local or regional development and land-use plans?
• Have the environmental consequences of power transmission and fuel storage been considered in site selection?

B. Project Design and Construction

• Will the power-plant construction activities be carried out in a manner that will minimize damage to the natural environment?
• Is there a consolidated construction plan that takes into account spatial planning and ecological factors?
• Are road patterns, land excavations, fill sites, and refuse disposal activities consistent with good environmental protection practices?
• Will land in construction areas be restored by filling, grading and reseeding to prevent erosion?
• Will air pollution be a problem and, if so, how will it be controlled?
• How vulnerable is the power plant to surface subsidence, earthquakes, tornadoes, and other catastrophes?
• What is the extent and impact of the environmental degradation which could be expected in the event of such catastrophes?
• What steps are planned to avoid soil erosion and the silting of streams, as transmission facilities and access roads are constructed?

C. Operations

• What disposition will be made of solid and liquid residues (e.g., ashes, nuclear wastes)?
• How will fuel be stored?
• Are low-sulphur fuels available for fossil plants?
• Have alternative fuel schedules been developed?
• Does the disposal or storage method include adequate cassetting or neutralization to minimize the danger of soil or water pollution?
• What steps are planned to contain and reclaim ash dumps to avoid pollution of surface and groundwater by acid-laden runoff?
• If waste disposal into water bodies is planned , what will be the effects on aquatic life?
• To what degree will tidal action and currents dilute plant effluents?
• What provision will be made for controlling the release of radioactive waste material into water bodies?
• If additional units are constructed, what will the total load of radioactive waste materials be?
• Is the makeup of the plant's gaseous emissions known in terms of chemistry and volume?
• What downwind environmental effects can be anticipated with respect to humans, crops, forests, and wildlife?
• How can such effects be minimized?
• Will emission control equipment be installed ? If so , is the level of control adequate?
• What impact will thermal effluents have on the receiving waters?
• What temperature increase can be anticipated, and how will this affect indigenous biota?
• Is there sufficient water motion in the receiving bodies to dissipate heat effectively?
• Has the use of cooling towers or ponds been sufficiently explored?
• What is the probability of producing undesirable fog conditions through the dissipation of waste heat?
• What impact will the impoundment for a hydroelectric plant have in terms of the destruction of agricultural and forest lands, and habitats for fish and wildlife?
• What measures are planned to mitigate the loss of natural habitats for fish and wildlife?
• To what degree will archaeological and scenic values be affected?
• How will the reservoir and downstream flow affect water quality parameters, such as temperature, dissolved oxygen, nutrients, nitrogen concentration, hydrogen sulfide, and color?

D. Sociocultural Factors

• Will construction or operation of the plant adversely affect agricultural, economic or commercial practices in the area, such as farming or access ways in a reservoir impoundment area?
• Will plant construction cause displacement of peoples because of flooding, required rights-of-way or because of new opportunities?
• Will plant effluent adversely affect agriculture, aquaculture or related practices?

E. Health Impacts

• What new public health problems may arise from the project?
• Will changes in water velocities, temperatures and depth result in a more favorable environment for disease-bearing organisms?
• Will the changes in water patterns introduce disease-bearing organisms into previously unaffected areas?
• Will long-term exposure to gaseous emissions prove a significant health problem? 
• Are contingency resources available to deal with unexpected problems of health maintenance or disease control? ln the case of nuclear power plants, is there a contingency plan for dealing with emergency health problems and accidents in the event of an emergency?

F. Long-Term Considerations

• What provision has been made for industrial development associated with the power plant?
• What impact due to increased immigration will that activity have on the environment?

References

World Bank ( 1974) Environmental, Health and Human Ecological Considerations in

Economic Development Projects. The World Bank: Washington, D.C., U.S.A. 142pp.

World Bank (1975) Environment and Development. The World Bank: Washington, D.C., U.S.A. 33 pp.

World Bank (1977) Manual on General Environmental Protection for the Industrial Sector. The World Bank: Washington, D.C., U.S.A.