Environmental Impact Assessments are not as solid as they appear

Jan 16, 2023 Features / Columnists, Peeping Tom

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Kaieteur News – Environmental and social impact assessments (ESIAs) done without engagement of members of society should be rejected outright. These ESIAs are often undertaken to satisfy regulatory requirements rather than to arrive at a true and comprehensive picture of the array of possible impacts of a project.

In the 1960s and 70s, there were a series of spectacular failures of major projects undertaken in developing countries by international financial institutions (IFIs). Correspondingly there was the growth of greater environmental awareness within the developed world and this in turn led to the emergence of powerful environmental advocates and movements who demanded that greater attention be paid to the environmental impacts of major projects. This demand was later expanded to include social impacts.

Not only did ESIA’s become mandatory for financing of major projects, but developing countries were also pressured into passing environmental legislation as a pre-condition for sourcing loans. It is now obligatory for major projects to have ESIAs before financing can be obtained from international financial institutions.

Guyana was late with the passage of its environmental legislation. The Environmental Protection Act (EPA) of Guyana was not passed until 1996, and had it not been for the devastating effects of the Omai cyanide spill years earlier, it may have been delayed further.

The EPA Act was criticized as being written solely to meet the demand, by international financial institutions, for projects to be subject to Environmental Impact Assessments (EIAs). While the Act did address issues such as pollution, it was by no means a satisfactory piece of legislation to address the gamut of environmental concerns. As such, there was considerable justification for the argument that this highly defective piece of legislation was aimed at meeting the demands for EIA so as to ensure that the IFIs’ would approve major project financing.

EIAs have also been subject to criticisms over the lack of public participation in the process. Normally what happens is that the EIA is tendered out and the consulting firm engages in cosmetic, if any at all, consultations with those likely to be affected.  Stakeholder engagement has become a common feature of the EISA process but even when there are public consultations, the public is provided with little or very poor information to allow for any meaningful participation. The submissions of the public are often ignored and thus those most likely to have little influence in the final assessment and recommendations. Little attempt has been made locally to enhance models of participation by those likely to be affected.

Instead, the EIAs are dominated by technical jargon and inputs. But many of those preparing the reports lack the local knowledge, something that would better inform their assessments. For example, how many fisher folk were consulted when the EIAs were being prepared for the Liza 1 EIAs? How many fisher folk would have known, muchless to submit written comments? The stakeholder engagement process of EIAs are highly flawed and not geared towards meaningful stakeholder engagement.

Because of this highly flawed model of stakeholder engagement, the full extent and range of risks are not usually considered. When it comes to social impact assessments, there are so many variables involved that most EISA tend to have a limited coverage of the wide range of social impacts which ought to be considered, including impacts on gender and youth

The Consultants undertaking EIAs have been accused of often lacking the technical expertise and many are forced to partner with experts in order to produce the EIA report.

Data management in developing countries tends to be poor and baseline data is often not available. As such many EIA reports are ‘cut and paste’ jobs. In countries like Guyana where data collection is weak and often dated, this presents a major problem for making technical assessments. As a result, analyses tend to be premised on assumptions and presumptions rather than facts and figures.

To compound matters, there have been cases where the Consultants designing the EIAs have been accused of being in conflict of interest. Given the limited number of Environmental Consultants available, it is inevitable that there will be cases of Consultants, who have worked with or for the oil companies, having to undertake an assessment of the impacts of the oil companies’ operations.

These are not theoretical concerns. They have significance for the type and the quality of EISAs that are generated in relation to local projects. When the EISAs reports are therefore published, for public consumption, these issues need to be borne in mind.

Challenges to EISAs need to be made extremely early because we have persons in Guyana who have broken the Guinness Book record for speed reading. They have been known to approve EISAs faster than it took the Consultants to type up the report.

(The views expressed in this article are those of the author and do not necessarily reflect the opinions and beliefs of this newspaper and its affiliates.)    

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• (ESIAs), (IFIs), EPA, Guyana, Omai, Peeping Tom, stakeholder engagement

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