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Stabroek News

Quackery and impact assessments
published: Sunday | January 14, 2007

Trevor Yip-Hoi, Contributor


Trevor Yip-Hoi

'The environment' comprises the built environment, where humanity lives and interacts, and the natural environment, where other living and non-living things occur. The built environment has a profound effect on the natural environment, e.g., fossil fuel production begets transportation, lighting, air conditioning and communications, even as it may cause pollution and global warming that threaten wildlife and flora, not to mention human injuries and health problems. Yet, developers continually strive to increase profit margins by providing life's trappings, whether needed or just wanted, just as politicians seek to create jobs.

Two important principles arose at the 1992 United Nations Conference on Environment and Development: Principle 4 stated: "In order to achieve sustainable development, environmental protection shall constitute an integral part of the development process." Principle 17 stated: "Environmen- tal impact assessment (EIA), as a national instrument, shall be undertaken for proposed activities that are likely to have significant adverse impacts on the environment and are subject to a decision of a competent national authority."

Many developers also remain unaware that successful EIAs can save both time and money. Much has been written on the subject of EIAs, but here I will instead focus on some salient characteristics of successful ones.

Characteristic 1. Successful EIAs commence early in the project life cycle.

In order to expedite early consensus, project conceptualisation must incorporate a scoping exercise involving the proponent, planning and environmental agencies, consultants and public. Scoping allows identification of key concerns and alternatives to minimise impacts, e.g., a green residential development might be a more viable option than a golf course; or a developer may be unaware that a proposed site will threaten a sensitive coral reef, attendant opposition from environmentalists, or of technology to reduce pollution. Once a project begins, there is increasingly less space for effective solutions, which invariably become more expensive.

Characteristic 2. Successful EIAs are transparent to stakeholders.

With the exception of trade secrets, sharing of project information dissolves suspicion, fosters goodwill, increases dialogue and ensures that decisions consider stakeholders' interests and alternative strategies. Such strategies can be cost-competitive or even cost-reductive. Furthermore, developers should be mindful that their decisions are now under ever-increasing scrutiny from environmentally conscious consumers.

The Terms of Reference (TOR), which specifies how an EIA is conducted, must consider project specifics, including scoping feedback, to avoid (i) superfluous requirements that address non-issues, or (ii) lax requirements that fail to address relevant issues. The current practice of allowing a proponent's consultants to suggest revisions to a generic TOR is a conflict of interest and adds opportunities for omissions, irrelevance and unscientific thinking, even if the TOR is publicly reviewed.

Characteristic 3. Successful EIAs require competent regulatory authorities.

EIA is a science-based process. The regulatory bodies that participate in the EIA process must therefore be staffed with properly-qualified scientists (physical, natural and socio-economic) whose minimum qualifications permit a comprehensive grasp of issues and what is being asked of counterpart EIA specialists. How this gets accomplished - civil servant identity, changing the status quo, screening for qualified individuals, competitive salaries, etc. - lies in the domain of any competent public administration. Failure to do so is a gigantic waste of taxpayers' dollars, not to mention the time lost doing bureaucratic judo.

Characteristic 4. Successful EIAs involve legitimate interest groups informed by proper scientific thought.

A successful EIA process encourages stakeholder inputs. Public meetings are excellent fora for discourse. However, an environmental study, having been conducted by qualified experts, must ultimately be reviewed by qualified experts, who must also determine the relevance of inputs by stakeholders. It is imperative to distinguish between legitimate interest groups that understand the complexity and inherent compromise of all cost-benefit analyses, and an ever-increasing phalanx of pseudo-environmentalists with cliched arguments for compassion towards charismatic megafauna. To be taken seriously, and to prevent further damage to the EIA process in Jamaica, interest groups need to desist from fetishes with emotionalism and stop sleeping in beds of hidden agendas.

Characteristic 5. Successful EIAs are conducted by properly qualified experts.

EIA is a widely-recognised professional discipline and thus, like any other, requires some system of verification and accreditation of credentials. In Jamaica, the tail ends of nepotistic old-boys-network functions often see hapless developers falling prey to advice from 'experts' with qualifications as paltry as bachelor's or taught-course master's degrees. Some have apparently even sought legitimacy under the shady boughs of self-created consortia. A sad case of the blind leading the innocent? Or simply the vultures gathering where the carcass has fallen?

These liaisons rely on promises of smooth sailing because of contacts with influential persons in high places, a good "track record" or because "A so we dweet ina Jamaica, mon". It is now time to make the Jamaican EIA process hostile to opportunistic quacks and phonies.

Characteristic 6. Successful EIAs incorporate effective mitigation and monitoring to determine environmental effects.

And so the environmental permit has been granted and everyone is reasonably content. Now what? Firstly, there must be a proper policing system to ensure that developers strictly adhere to their original proposals. Secondly, it is crucial to ensure that stipulated monitoring and compliance terms are rigidly adhered to. After all, what is the purpose of implementing mitigation measures if there can be no proof that they actually work, and how can the environment be safeguarded if there is no measurable comparison (i.e., based on statistics) of before and after scenarios? A dog with no teeth is soon a dead dog.

Dr. Trevor Yip-Hoi is vice- president, Environmental Affairs, Cool Group of Companies.

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