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Environmental impact assessment : effects on corporate mega-project planning Olynyk, John Murray

Abstract

Environmental impact assessment (EIA) is intended to be a means of increasing the level of consideration of environmental factors in planning and decision-making. The ultimate objective of EIA is to prevent needless harmful environmental change resulting from human development activity. EIA, therefore, is a government review process aimed at development proposals from both the public and the private sectors. This study examines how the existence of EIA requirements has affected project planning by private corporations involved in large-scale resource developments. Two current resource developments in Canada are the Beaufort Sea Hydrocarbon Development and the Northeast Coal Development. The EIA processes being applied to these developments are, respectively, the federal Environmental Assessment and Review Process (EARP) and the British Columbia Coal Guidelines Review Process (CGRP). While the proponents of the two developments are given the responsibility for providing the information upon which the EIA's are based, they must also bear a large proportion of the costs of the EIA processes. The EIA requirements had limited positive and negative effects on the proponents' project planning. The proponents of the Beaufort development feel that the public review phase of EARP has not contributed substantially to the quality of their project planning and design. This they attribute to their normal high standards for planning and design work, and also to the considerable overlap and duplication in the existing environmental regulatory regime. The main benefits of EARP were characterized as community-relations and corporate image benefits. The EIA stage of the CGRP did lead to a small number of changes being made to project designs and plans. However, these could not be attributed solely to the EIA, as they may have been made to facilitate negotiation of statutory permits and approvals in the post-EIA stage. Neither development has been delayed by the EIA requirements. The strong government support for the Northeast Coal Development was demonstrated by Victoria's decision to allow construction to proceed before EIA approval was granted. This was necessary to meet tight project deadlines. EARP has not delayed the Beaufort development because, to date, insufficient reserves of oil have been proved for the proposal to be commercially viable. Because EIA is not treated in isolation from the proponents' project planning, only rough estimates of the additional costs of EIA were available. While these costs were estimated in the millions of dollars, they represent only a small proportion of overall development costs. It was not possible to determine whether more efficient reviews could have reduced these costs. Comparison of the public and private benefits of the EIA processes was not attempted due to difficulties in identifying and quantifying those benefits. The two EIA processes did not appear to be an integral part of the proponents' project planning processes. EARP and the CGRP are designed to meet the governments' decision-making requirements, as opposed to industry's planning requirements. They are not, therefore, structured such that they contribute directly to industry's environmental planning needs. In fact, the degree of integration of EIA into the proponents' planning process does not necessarily reflect their level of consideration of environmental factors. The proponents' normal project planning practices appear to address the same concerns that EIA is intended to address, partly due to corporate policy and partly to meet the requirements of other government regulation. Despite this, EIA is a necessary component of the present project review and regulatory process. EIA processes provide information for government decision-making, and are important means by which the government and the public attempt to ensure that industry adequately considers environmental factors in project planning. However, steps should be taken by government to integrate EIA and environmental regulation into an ongoing process of impact management, operating through all stages of resource development.

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