Recently, the release of environmental impact assessments (EIA) or lack thereof has generated much attention in the media. But why are EIAs so controversial?
Defining environmental analysis
An EIA is just one of several document types used to identify, mitigate and manage potential impacts, natural, social or economic, of a specific project. Essentially, this process of environmental analysis seeks to uncover the cumulative effects of a project by comparing the existing conditions with the anticipated conditions associated with the actual implementation of the project.
The purpose of the EIA is to identify potential impacts, positive or negative, of a proposed development. It is a tool to assist with the ongoing challenge to balance the preservation of natural resources while accommodating the demand for economic development. The EIA functions like an umbrella capturing information pertinent to a multitude of ministries, including the Office of the Prime Minister, the Ministry of Works and Urban Development, the Ministry of the Environment and Housing, the Ministry of Agriculture and Marine Resources, etc.
Environmental analysis is about more than just the trees and birds; it attempts to satisfy growing demand for consideration and accountability of quality of life issues. Simply acknowledging the process of environmental analysis as part of community planning reflects increasing affluence and changing attitudes on the meaning of national development.
Demand for environmental accountability
Tellingly, the recent public commentary on EIAs and environmental matters mirrors an increasingly educated audience. Such interest stems from expectations for a higher degree of transparency and oversight by the government on undertakings that affect our community. Furthermore, the digital age and the expansion of access to the Internet have revolutionized the dissemination of information with greater awareness for accountability.
In fact, the United States Congress passed the National Environmental Policy Act (NEPA) in 1969 to placate voter demand for federal commitment to address pollution. Republican President Richard Nixon signed NEPA as his first official act of 1970 and went on to establish the U.S. Environmental Protection Agency later that year. NEPA set the foundation for the environmental impact statement by requiring environmental analysis on "all major federal actions significantly affecting the quality of the human environment".
Despite its imperfections, it is widely acknowledged that NEPA prompted greater environmental awareness, and more importantly, compelled a higher degree of risk analysis and planning across all federal agencies and industry sectors.
But NEPA also requires federal agencies to inform the public that environmental concerns are part of the decision-making process. Thus, NEPA constitutes a platform for public participation in the federal decision-making process.
With NEPA, the United States set the precedent for environmental impact analysis and public participation as part of the due diligence process on major government supported projects. This practice has proliferated since 1970 where some form of environmental analysis, including public participation, is now a prerequisite by most countries, including The Bahamas, and multi-lateral lending agencies.
What then is the EIA controversy?
An EIA provokes contention because its content is subjective. Ambiguous terminology like significant and major influence the findings of an EIA with potential detrimental ramifications for a project, yet such findings depend largely on context and the professional capabilities of the EIA author and reviewing agency. It is not surprising then that environmental reports are the subject of litigation, though the incidence of such litigation has declined in the United States.
It can be exceedingly difficult to determine the exact point at which the economic benefits of a project outweigh the potential harmful environmental consequences, an issue of much dispute regarding the North Bimini Ferry Terminal. Though here, the Bahamas Environment Science and Technology Commission (BEST) acknowledges third-party assistance with the review.
But controversy also arises not entirely from the impact evaluation per se; it is also prompted by the failure or perceived failure to adequately engage stakeholders in the planning process, particularly for major government projects. This perceived exclusion defies the generally accepted principle that public commentary is an integral part of the environmental impact assessment for a project of major community influence.
Certainly, confidential business information precludes the dissemination of details, particularly at the initial stages of development before construction commences. But such withholding of information places the government in a precarious position; can an EIA be considered complete without public consultation? Government policy to pursue a form of environmental assessment as a condition of approval rests on the perception of public inclusion which is not necessarily so.
Is environmental analysis effective?
Environmental analysis recognizes that project influences can extend beyond the perimeter of a geographical boundary. An EIA identifies and determines whether these project influences will be beneficial, detrimental, or of no consequence to the proposed changes to our existing community. Such a holistic approach to project evaluation is indeed novel.
But unless the EIA findings are incorporated to the project plan, and the recommendations implemented through environmental management and monitoring, the document itself is just another report.
Additionally, while this umbrella type of analysis captures impacts across ministries and disciplines in a single document, the breadth of the impact assessment also becomes its burden. Stipulations for environmental analysis were not intended to breed documents numbering hundreds of pages long. Such length impedes timely review, and likely contains repetitive information which detracts from core issues.
Though a scoping meeting with BEST is designed to narrow focus and highlight potential areas of concern, the document and review process are anything but streamlined. Breakdowns in communication and lengthy review times pose inconveniences to potential investors who expect a serious show of commitment by government.
But despite its obvious shortcomings, environmental analysis is a critical part of project evaluation, and improvement to the process is not as difficult as perceived.
The future of environmental analysis in The Bahamas
Indeed, it is up to the government of The Bahamas to facilitate economic growth while ensuring natural resources remain for future generations. Environmental analysis can be an effective mechanism to achieve sustainable development. However, much has changed since the 1970s and the process of environmental analysis must reflect technological and scientific advances.
Environmental impact assessments contain important data on site specific biologic and cultural resources but few, if any data, are compiled into a Bahamas database for future reference.
There is woeful collection, consolidation, and public access to the scientific literature produced by researchers in The Bahamas. Redundant collection of baseline data impedes efficiency, and standard climatic data could be produced by the government for the northern, central, and southern Bahamas.
The EIA process must be streamlined with a transparent policy approach that gives investors clarity and accountability for timely review by the government.
Public consultation, where deemed appropriate, need not be constrained by public meetings; electronic requests for comments would engage a technology savvy youth.
Moreover, the upcoming generation of Bahamians participates in environmental education and expects more access to information than previous generations.
We must accept that development is inevitable. We must also accept that our natural environment is a considerable asset to The Bahamas, if not the most important, to attracting investment, particularly in the tourism industry. Too often these two elements exist exclusive of the other when both are necessary for growth.
o Melissa Bray Alexiou is the director of Waypoint Consulting Ltd., a project management and environmental consulting firm in Nassau, The Bahamas. For more information visit www.waypointconsultingbahamas.com.
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