Time to re-consider environmental impact assessment?

September 6, 2012

The publication of draft revised Guidelines on Environmental Impact Assessment for Planning Authorities and an Bord Pleanála brings to mind the on-going development of impact analysis at both national and international level. Some might argue that it is regrettable that the thinking set out in the new Guidelines was not available to the planning system during the past decade where concern for sustainable development was measured more in the impatience to approve ill considered develops expressed by the media and various political voices and developers, than in the need to have clear regard for the legacy effects of such development.

While it might be the case that the horse has well bolted, at least the new guidelines reflect a more considered perspective on the need to clearly integrate sustainability into the evaluation of planning submissions and that the planning profession is provided with a firmer basis for the evaluation of proposals.

That said it is useful to consider where the international context on impact assessment has developed. Increasingly it is evident that the international investment community are looking beyond the immediacy of the impact of development on the natural environment when taking investment decisions that seek to reflect best international practice. Reflecting the on-going thinking on sustainability, impact assessment is now seen in terms of the balancing of human develop needs with the critical requirement to sustain and protect the earth’s natural resources.

The environment is thus seen in its proper context, as that of being central to economic, social and cultural development and not just an add nuisance in financial project assessment and due diligence. Thus, increasingly, planning processes are being looked at in the context in which independent perspective is applied to development proposals where environmental considerations are a central aspect. The simple justification of programmes, plans and projects on the basis of a simple thematic analysis is no longer acceptable to the international investment community. Given Ireland’s dependency on international investment decision-makers, this is something which absolutely must be understood if the country is to continue to deliver international investment.

Environmental impact assessment is therefore no longer a development hurdle to be gotten over. Rather and increasingly, it is a feature of an integrated decision corridor which places development within a social, cultural and environmental context and which uses the economic benefits derived form the proposed investment as a platform for sustaining the local and national economy. This thinking brings the principles of sustainability back to its origins in the Bruntland Report but does so in the knowledge that the environment is central to a sustainable society which seeks to reduce social disadvantage and sustain cultural diversity.

As a result major investment decisions now seeking funds from the international investment community have to undertake iterative project design which is based upon international performance criteria such as those developed by the International Finance Corporation, the European Commission and other international players.

So what does this mean for what is still one of the richest countries in the World, despite recent economic events?

Clearly the fact that Ireland is now more dependent on having access to both private and international public investment funds means that our systems have to be re-considered. In part this is reflected in the recent draft guidelines. More significantly however, is the reality that projects which will be dependent upon international investment will have to be prepared having a clear understanding of international investment criteria such as those developed by the IFC.

Broadly this means that projects, plans and policies:
• should not result in significant negative impacts on the target population(s)
• must not result in non compliance with the relevant national/international policy.
• should not result in non-compliance with the relevant local policies.
• should be subject to review over the duration, leading up to and beyond, the completion date of the policy, programme or the closure of the facility.
• should minimise the potential for negative impact on the environment and should maximise the potential for environmental benefit.
• must be capable of responding to unforeseen scenarios during the implementation of the tasks and actions underpinning the policy, programme or project.

So, in addition to the development of the new guidelines, it may now be time to commence an overall review of the comprehensive body of regulation in Europe generally, and given Ireland’s current economic exposure, the regulatory framework for Impact Assessment in Ireland, to ensure that comprehensive assessment reflects the thinking now clearly enumerated in the international investment community.

Time now to fully integrate poverty, gender, health, social and cultural perspective into the Assessment process?