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% 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}
Applicants of resource consents are required to produce ...
The RMA requires an Assessment of Environmental Effects (AEE) to be
prepared for every activity
- 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)''.
% - opportunities for public involvement?
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 \parencite{TODO}. % TODO
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 in the two-year period were notified
in some way, with only 4 per cent being publically
notified \parencite{rma-survey}.
- limited opportunity for the public to influence decisions
On the other hand, public participation ... leads to abuse, slow process miller2010implementing
\subsection{Cumulative effects}
What sets apart New Zealand's approach to environmental assessment
from those of other countries is the devolved mandate. The
distribution of responsibilities to the local levels of government,
however, brings about difficulties in effective environmental
management. Project-level EIA usually does not address cumulative
effects well, i.e. individual minor effects of several projects that
result in serious impacts when combined, because this would require
regulation and monitoring at a higher
level \parencite{eia-state-of-the-art}.
When resource consent applications are processed independently from
one another at the local level, their aggregate cumulative effects are
easily overlooked. Although the RMA specifically includes cumulative
effects in the definition of effects that have to be considered
(Section 3), it is still up to the council to review an AEE with
regards to cumulative effects. The quality of this review crucially
depends on the experience and the resources available at the local
level to scrutinise an AEE that may not properly address cumulative
effects \parencite[p 267]{furuseth}. A joint hearing process has been
used in the past to successfully overcome this limitation for
individual projects that require multiple resources consent
applications to be considered \parencite{fookes}.
When the cumulative effects of more than one proposal are to be
considered, ... need coverage by plan/policies at national/regional
level + monitoring.
% This is one of the reasons for the birth of Strategic Environmental Assessment.
- very slow publication of NPS and NES at the national level
\textcite{miller2010implementing}
- hence: few constraints on local plans, leading to regional differences
- 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 plan-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}
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