Environmental Assessment of Project Alternatives – how much should be included in an EIA?

Last week my local paper included an invitation from the Council to comment on a proposed road extension, so having an interest in these matters I took a look at the EIA document and was immediately struck by the absence of any consideration of alternatives. If you look at the figure showing the road alignment on the DSEWPaC website (sorry I can’t reproduce it here because of copyright restrictions) it is apparent that that there are at least two alternatives with potential reduction in environmental impact exist but have not been described.

Guidelines issued for environmental impact assessment under most States and Federal environmental legislation include the requirement for an analysis of alternatives. The most common response by proponents to the guidelines is to only put forward a limited selection of alternatives for assessment, if any at all, that reflect narrow project objectives. Furthermore the description of the alternatives that have been put forward is often subjective and written with the intention of discounting all alternatives other than the chosen one. This reponse makes it almost impossible for either the regulator or public to conduct a rigorous analysis of alternatives. However it does not necessarily follow that the proponent has not prudently considered all feasible alternatives.

As with any business activity there is a wide variety of techniques to select from when dealing with alternatives in project development. It is important to remember that the activity of conducting a review of alternatives and the activity of reporting on alternatives in an EIA document are two separate undertakings. It is informative to visualise these two undertakings as axes of a grid (as shown below). The horizontal axis is a representation of how much effort is directed towards conducting an environmental assessment of alternative project options (such as location or manufacturing method). The vertical axis is a representation of the amount of detail of this environmental assessment of alternatives provided within the EIA documentation.

Effort v Reporting GridIn an ideal world we would see EIA documents in the upper right corner where the proponent has undertaken a comprehensive review of alternatives and provided detailed quantitative information on the alternatives within the document. Such a situation would satisfy the spirit and intent of the guidelines. I am unaware of any studies that examined EIA documents from the different jurisdictions to gauge how what proportion of the documents would meet these criteria. I suspect it would be a small portion. In my time I have been involved in several projects that score in the bottom right hand corner of the grid, having conducted large-scale review of alternatives but chosen to give little or no information on the alternatives considered in the EIA document. I am also aware of projects where there has been no environmental assessment of alternatives during project development yet the EIA document presents a review of alternatives written to discount all alternatives (that were never seriously considered anyway).

In the coming days I want to delve further into the issue of alternatives in the EIA process, in particular how to find the optimum balance between environmental assessment of alternatives undertaken by the proponent and the description of alternatives presented in EIA documentation.

 

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