% discussion 1000
% - common issues in EIA      400
% - evaluating NZ's approach  600

\section{Discussion}

This section discusses common problems of EIA implementations as they
relate to the RMA, as well as issues that New Zealand's integrated and
devolved approach to environmental assessment brought about.


\subsection{The quality of assessments}

- poor environmental models / baseline => precautionary principle

\textcite{practitioners}
- volume of assessment work, enormous breadth in scale of covered projects
- those producing an impact assessment are not necessarily skilled in AEE
- EIA education is secondary concern for pracitioners (one day courses on AEE)
- strong professional ``imprint'' on the AEE process, no common language
- no strong central guidance on impact assessment practise --- what is considered adequate is not defined
- according to survey of practitioners checklists are most often used, matrices and expert EIA systems are not; checklists are overly simplistic.
- Fourth Schedule of the RMA was most often cited as an issues checklist for assessment
- assessments are not seen as enabling affected parties to get involved in decision-making --- although this is one of the core principles of EIA
- results: AEEs are primarily done to fulfill the requirements of the Fourth Schedule, not concerned with meeting international EIA standards/best practise.


% TODO
http://www.mfe.govt.nz/publications/rma/review-consent-processing-performance-round-one-jan08/html/page4.html
poor quality applications are rarely refused as permitted by section
88(3) of the RMA. Once they have been accepted, inadequancies within
the application are addressed through the use of section 92; this
approach not only delays the processing of resource consents, but also
increases the likelihood of poor quality applications to be granted.


\subsection{Participation of the public}

Although the use of objective measurements and scientific methodology
is considered EIA best practice \parencite{principles}, EIA is neither
science nor is it an objective process.

% TODO: not science: predictions made on the basis of very limited inputs

As environmental impact statements are produced by project proponents
with the goal to convince decision-makers of the benefits of the
project in question, the report is a subjective statement or even a
piece of project advocacy \parencite{TODO}. In recognition of this
inherent bias, the EIA process calls for the participation of the
general public, in particular the participation of affected
individuals or interest groups \parencite{wilkins}.

It is therefore rather disappointing that even in recent reviews of
international EIA practise, public participation remains on a fairly
low level \parencite{eia-state-of-the-art}. According to
\textcite{RMIT University \& UNU Online Learning. (n.d). Environmental
Impact Assessment Open Educational Resource.} ``there is little
opportunity throughout the process of EIA for the public to be
involved; where involvement is possible it is often limited due to
lack of resources (time and expertise)''. Some of the main barriers to
public participation cited by \textcite{eia-state-of-the-art} are:
poor knowledge of the public about the process; poor provision of
information; failure to influence the decision-making process; poor
execution of participation methods; and regulatory constraints. As a
review of resource consent processing performance in New Zealand
indicates, especially the latter three are significant obstacles to
public participation in New Zealand. According to the 2010/11 survey
of local authorities the New Zealand Ministry for the Environment
carries out every two years, only about 6 per cent of all resource
consents were notified in some way, with only 4 per cent being
publically notified \parencite{rma-survey}. This means that of 36,154
resource consents that were processed across the country over a period
of two years, the public was able to provide input on only 1,414
proposals.
 
- opportunities for public involvement?

  - limited opportunity for the public to influence decisions

  

\subsection{The problems associated with devolution}

What sets apart New Zealand's approach to environmental assessment
from those of other countries is the devolved mandate, meaning that
most resource consents are processed at the lowest level of
governance, by district or city councils.

- cannot deal well with cumulative effects, because that's best done
  on a national/regional level \parencite{eia-state-of-the-art}

- most resource consents are processed at the district/city level, not
  at the regional level

- \textcite[p 267]{furuseth}: little experience or resources to
  scrutinise EIA on the local level


\subsection{Monitoring and follow-up work}

- insufficient monitoring (68\%) \parencite{rma-survey}

- one-off projects that don't improve the knowledge basis or affect
  the assessment of future projects \parencite{follow-up}


\subsection{EIA at the policy level}

``Environmental Assessment in a Changing World'' (EAE_10E.PDF, Sadler)
\begin{quote} (page 49)
  [EA under the RMA] ... is indirectly specified for policy
  statements and strategic plans which local authorities are required to
  prepare to guide and implement sustainable resource
  management. Application at this level is variable and, overall, it is
  concluded that the unique way that EA is integrated into the Act makes
  evaluation of the effectiveness of implementation difficult
\end{quote}

(page 164[pdf], 146[published])
\begin{quote}
  SEA is intended to be an integral part of
  policy and plan-setting, rather than being applied to them as a
  separate procedure. The resulting framework, in turn, establishes a
  context and parameters for subsidiary EIAs, which are required for all
  resource use consents and where the presumption is for protection via
  rigorous limits on discharges etc. However, in practice,
  implementation of the Act is occurring slowly. Experience to date
  indicates that local governments still rely on project EIA rather than
  undertaking policy and pian-level assessments,
\end{quote}

\subsection{TODO: Effective? Does EIA bring about sustainable development?}
\textcite{retrospect}:
``EIA generally continues to bring about only relatively modest adjustments of development proposals.''
  also seems to apply for NZ resource consents:
  - only a little more than half a percent of all resource consents are declined \parencite{rma-survey}



  
\subsection{Scratch}

\parencite{beattie}:
   - cannot be science because it makes predictions based on very limited data
 - EIAs are always political because they are part of a decision-making process
 - EIAs are necessary because they add valuable information to public
   discussions on specific proposals

- poor communication
- failure to predict important impacts

The following is from \textcite{RMIT University \& UNU Online Learning. (n.d). Environmental
Impact Assessment Open Educational Resource.}:

- screening is political because it depends on the values of those who perform the screening

checklist from \textcite{intl-perspective}