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

\section{Discussion}
TODO

\subsection{Common deficiencies of EIA implementations}

\subsubsection{Inherent limitations of EIA}
\parencite{beattie}:
 - EIA is not science
   - cannot be science because it makes predictions based on very limited data
   - may not be advertised as science because it would not stand up to scrutiny
 - based on value assumptions and inherently biased
 - 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

\subsubsection{Other deficiencies}

- limited opportunity for the public to influence decisions
- poor communication
- one-off projects / lack of monitoring and follow-up \parencite{follow-up}
- failure to predict important impacts
- poor environmental models / baseline => precautionary principle

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
- although political in nature, 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)

\subsection{Evaluating New Zealand's approach}

``Social Assessment'' (Taylor et al in the Green Book, chapter 25)
\begin{quote}
   The New Zealand Resource Management Act (1991) is regarded by many as the
   foremost and most innovative national legislation for environmental assessment in recent
   years. This act has included mandatory requirements for the assessment of environmental
   effects, with “social,” “cultural,” and “amenity values” clearly included in the definition
   of environment. Also required are public involvement and community consultation, and
   monitoring of effects once the plan or project has begun.
\end{quote}


checklist from \textcite{intl-perspective}:

- opportunities for public involvement?
  - only 6\% of resource consents were notified in some way, meaning that the vast majority were granted without involving the public \parencite{rma-survey}

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

- problems of devolution:
  - 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{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.