 |
|
 |
|
 |
|
 |
|
 |
|
ENVIRONMENTAL STATEMENTS
Environmental statements are required by law to ensure that the environmental impacts of larger industrial activities are considered. They accompany the consent application for such activities and may ultimately form part of the permit itself.
Being required by law, environmental statements are compliance driven and this often results in an attempt to justify the proposed activities. This should be avoided. The approach suggested here is different in the sense that it produces documents that are issue driven. These documents aim to address all of the environmental questions that stakeholders may have; not just the ones that are asked by the regulators. Such environmental statements tend to cover more ground, but are less bulky nonetheless.
Examples of such statements are listed on my clients and projects page.
I have found the following structure for environmental statements particularly effective:
- Description of the development.
- Description of the environmental sensitivities.
- Issue identification and characterization.
- Risk management and risk communication.
Development description
The aim of the development description is to describe the proposed activities so that these can be understood by those that may be concerned about them. The description should be detailed enough to allow for the understanding of the mitigating measures.
The societal benefits of the proposed activities are also described, even though these are outside the legal scope of the environmental impact assessment. The societal benefits of a project should outweigh its environmental impacts.Environmental description
The aim of describing the environmental (and socioeconomic) sensitivities is to acknowledge these sensitivities and more importantly to inform the description of if and how these could be impacted. Only those sensitivities that can be impacted need to be described in detail.
It can be argued that the environmental description needs to be more comprehensive and describe additional sensitivities that are of specific interest to stakeholders, but it should be realized that a detailed description offers no protection by itself. The seriousness of cumulative impacts, for instance, is not only determined by the sensitivity of the environment, but also by the burden already placed upon it.
Issue characterization
The purpose of identifying and characterizing specific environmental concerns associated with the development is to focus the environmental impact assessment and to ensure that the mitigating measures and communication strategy are appropriate and effective. My pages on issue identification and issue characterization suggest a methodology for achieving this in greater detail.
Risk management
The risk management and risk communication part of an environmental statement communicates how the environmental impacts of the project are being managed. I suggest that environmental statements do this in an issue by issue basis in the following manner (see also my page on risk communication):
First, a description is provided of the developers understanding of the environmental issue in question, so that the various parties can agree that it is the issue that needs to be managed. This means that the party that has the concern is acknowledged and this in itself will reduce polarization. Very often this first step is overlooked and concerns are accepted at face value, sometimes providing legitimacy to concerns that are substituting for deeper, underlying concerns.
Secondly, a description is provided of all the (developer’s) activities which relate to the concern. This step helps to further clarify the scope of, and hence responsibility for the environmental issue. If the concern is, for instance, about air quality, then all potential sources of atmospheric emissions should be described.
Thirdly, any gaps in understanding are highlighted. It is important to identify gaps in understanding because they present opportunities for engagement. There is a strong tendency to avoid naming gaps in understanding as that implies that the developer is not in control of the environmental issue. It is often more comfortable to brush them aside. Ignoring what we don’t know does, however, tend to backfire. A technique that I criticize is to present a fast amount of scientific information aimed at dazzling the reader. I call these constructions ‘citadels of science’.
Finally, a summary is presented of the measures which have been implemented to reduce the likelihood that an environmental impact will occur together with an explanation of how any gaps in understanding are managed. This basically describes how the environmental issue is being managed and opens it to criticism. The description avoids to draw conclusions, such as that the issue is insignificant, or acceptable. Instead, the description is aimed at providing the reader with enough information to make this judgment him or herself.
