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3. Detailed assessment of environmental impact
3.1 Procedural context
3.2 Authorship of EIRs
3.3 Contents of EIRs and standards of adequacy
3.4 Timing of detailed assessment
The most elaborate stage of EIA consists of the preparation of a detailed, formal document the Environmental Impact Report (EIR)1. The need for are,. scope of this document will have been determined during Screening or Preliminary Assessment of, the forestry project (figure 1). The EIR can. be either partial or full, depending on the findings of these earlier stages of EIA. A partial EIR may be one that for example, considers only the biophysical environment as the project area is located in an uninhabited region, and no permanent settlements or other infrastructure are contemplated.
1 The neutral term "report" is used deliberately in preference to "statement" because of the legal connotations of the latter in North America.
As emphasized earlier, request for a formal EIR is a measure of last resort, to be adopted only under compelling circumstances. Those circumstances might be large-scale logging in critical watersheds, felling and forest-road construction adjacent to a national park, logging in a hitherto inaccessible area supporting only traditional subsistence economies forgot clearing in an area clearly identified as having outstanding scenic or scientific value, or the establishment of an integrated forest industry in a region where agricultural and other labour is already source.
If all of EIA is an aid to decision making, this is all the more true in the case of a formal impact report. Accordingly, the EIR is structured and written around areas of concern and issues requiring decisions. It avoids lengthy descriptions that do not contribute to an understanding of critical environmental sod other issues. The function of an EIR is to enable decision makers to weigh the costs and benefits of a forestry project, of various modes of development including different scheduling, and above all, of alternative locations for the project.
It is envisaged that the preparation of EIRs would form part of the feasibility studies of forestry projects, on a part with technical evaluations and economic cost benefit analyses.
EIRs might be prepared by the proponents of forestry projects be they private enterprises or state corporations, either by the proponents' own environmental staff or by experts retained for the purpose. Alternatively EIRs could be prepared by the environmental regulatory agency this procedure being set in motion by the application for a logging concession or other forestry or forest-industries permits. International organizations in the technical assistance field may have a role to play in the preparation of EIRs. The question of authorship of EIRs is dealt with at some length below.
EIRs are likely to be increasing submitted to funding agencies alongside technical and economic evaluations of forestry projects. Many of these agencies have, or are in the process of establishing, environmental review procedures. EIRs would be submitted simultaneously to national or regional environmental review bodies or officials. The latter will vary, depending on the circumstances of a particular jurisdiction. For example, where proponents prepare the EIR, this document might be reviewed by the environmental regulatory agency. In countries where the regulatory agency is the assessor the Minister of the Environment or of Natural Resources might be the official reviewer. In small countries with a large forestry sector the review body might be the Cabinet, particularly in the case of large projects. Some jurisdictions may appoint an independent review board or commission for the purpose of examining EIRs.
Practice has shown that it is often the proponent of a project who prepares the EIR, either directly or through a consultant hired by him. Despite the obvious risk of conflict of interest, there are several practical reasons that argue in favour of this approach.
One key reason for this approach is financial equity, as the proponent should pay for the administrative costs created by a project from which ho stands to gain. However, in some cases a proponent may incur high expenses for EIA because ho is forced road by the government to locate his project in an environmentally sensitive area for reasons of regional development or economic decentralization. In such cases, the proponent should not be made to bear the entire financial and/or administrative burden of EIA.
A second reason is that, in many jurisdictions, the environmental regulatory agencies have neither the time nor the manpower to prepare EIRs. From the standpoint of administrative efficiency, it may also be desirable that the agencies concentrate on their primary task of regulating and reviewing actions or documents concerning the environment, rather than dissipating their energies in matters of data collection or methodology of impact prediction.
A third reason is that an environmental team completely independent of the proponent often cannot function efficiently because of the constant need to consult technical personnel planning the project on possible actions (see Glossary A). There is also a need to closely with project management if the project is to be modified in an environmentally advantageous way during he design stage. It is also impractical for an environmental team to define alternatives solely on environmental ground without prior consultation with technical and economic exports. As described later, alternatives that drastically changes the techno economic bases of a project run the risk of being dismissed at the review stage as "unreal" alternatives. Substantial redesign of a project should only occur when all alternatives show unacceptable environmental damage. In general, "parallel" or separate planning by environmental and techno economic teams requires at some point the fusion of plans, and this fusion is usually difficult and time consuming.
As noted above, with the proponent preparing an EIR, there is a risk that the EIR, becomes a self serving document. The risk of conflict of interests can, however, be minimized by means of the following measures:
(1) Minimum standards of format and contents should be set by the reviewing agency:
(2) EIRs should be reviewed by an independent body with the authority to rule on the adequacy of these documents; in this respect, some countries may want the assistance of international conservation bodies (see Annex C);
(3) Mandatory consultation with local residents and with regulatory agencies should be required during preparation of the EIR;
(4) Consultation with scientific authorities, such as the country's central research institutes, national herbarium, or academy of sciences, should be made part of normal EIA procedure;
(5) The data presented should be verifiable by third parties;
(6) The EIR should be regarded as a public document that can be scrutinized by the public and by independent experts, with duo regard for the protection of industrial or trade secrets;
(7) Authors of EIRs may be asked to testify or to be cross-examined in hearings before review boards.
Experience has also shown that environmental experts involved in the preparation of EIRs are generally unwilling to jeopardize their professional reputations with biased work. Indeed, the very fact of employment by a proponent tends to act as a spur to objectivity particularly if the EIR is to receive full public scrutiny. Some countries also require that individuals responsible for EIRs meet certain qualifications, such as membership in scientific or professional societies. In turn,, some societies (notably the Ecological Society of America) have issued codes of ethics for members who engage in public environmental work.
A further device whereby regulatory agencies ensure that EIRs prepared by proponents are objective is the issuance of terms of reference specific to a particular project. These terms of reference or directives can take the form of a detailed table of contents of the prospective EIR, with additional instructions as to which aspects need to be emphasized. The directives may also prescribe the number of alternatives to be considered, the methodology of impact prediction to be used, and certain general principles, such as the principle of non interference with water quality or a particular scenic view.
In those jurisdictions where the regulatory agencies have the personnel and the time to prepare EIRs the risk of biased reports will, of course, be reduced. However, regulatory agencies should not underestimate the need to work closely with the proponents in defining alternatives and] in modifying the project to accommodate environmental concerns while the design is still fluid.
A hybrid procedure may be for the regulatory agency to retain a team of environmental experts (say from a university or research institute), , and to assign this team to the project staff for the purpose of EIA. Cost of this team may or may not be borne by the proponents depending on whether or not environmental planning is considered a general government function supported by general revenue. The integration of an outside team into a project-planning staff may pose some problems.
In developing countries, where the regulatory agencies may be understaffed and environmental consultants non-existent, the universities may have to play a key role in training and seconding environmental specialists for and to government agencies and private proponents who need to prepare EIRs. Separate "Institutes" or "Departments of Environmental Studies" would not only train and make available staff skilled in EIA, but would gradually build up regional or national banks of environmental data to be used for future EIA and land-use planning. The seconding of staff to proponents would also yield revenue to the universities, who can then expand environmental research and training accordingly. The use of university staff for EIA would also mean impact reports prepared by third parties, with benefits such as objectivity and the possible avoidance of strained adversary relationships between proponents and regulatory agencies.
By relying on universities or research centres for temporary staff, regulatory agencies that have to prepare EIRs may also avoid the staffing problems associated with uneven workloads.
3.3 Contents of EIRs and standards of adequacy
3.3.1 Description of the forestry project
3.3.2 Evaluation of alternatives
3.3.3 Mitigation, phased analysis and monitoring
3.3.4 Agencies, individual and literature consulted
3.3.5 Relevant legislation, regulations and licensing
3.3.6 General editorial requirements
The contents and standards of adequacy of EIRs described below are proposed as ideals from which it may often by necessary to deviate because of limitations of data, funds, time, relevant staff and the sheer logistical difficulties of collecting field data, especially in the humid tropics and in mountainous terrain.
3.3.1 Description of the forestry project
The EIR should contain a summary technical description of the forestry project being assessed, including an indication of the ultimate expansion of the project if the latter is to be in phases. This summary description is intended for the reviewer(s) of the EIR who may not have access to the full project description or the time to become familiar with it. A statement concerning ultimate expansion is needed because regulatory agencies should issue permits on the basis of projected cumulative impacts (cf. below).
The summary description of the project should emphasize activities or actions that are likely to have an environmental impact. For example, alternative harvesting or industrial methods or processes should be cited only to the extent that they generate different types of wastes or have different impacts on the landscape.
The description of the project should indicate the impact region (see Glossary, Annex A) used for purposes of EIA. It is common practice for a proponent to describe a preferred project site or area and its impact region, and the same for each alternative considered (see 3.3.2). A biophysical impact region may differ from the socio-economic one, in which cases both impact regions should be shown. Socio-economic impact regions tend to be larger, owing primarily to economic multiplier efforts. The impact regions of two alternative may, of course, overlap.
As implied above, the project description should include maps, ideally at scales of 1:50000 or larger (smaller areas shown). At scales of 1.100000 or smaller, too much detail is lost.
The description of the project should state the socio-economic and technical criteria used for the selection of project sites or areas. Above all, the report should state clearly the minimum (sine qua non) conditions needed to ensure the economic and technical viability of the project. Without this information it is impossible to discuss reasonable alternatives or project modifications.
The project should be described in the context of regional forestry development, if pertinent. The project should also be discussed in relation to regional, national or any other relevant land-use planning framework. This overall context allows reviewers to judge possible cumulative impacts.
It is worth stressing in this connection that EIA is ineffective in an institutional vacuum. Ideally it should take place within the framework of regional or national Land-use planning. The basic reason is that the scale at which single-project EIA takes place is inadequate for decisions that ought to add up to far-sighted regional or national use of natural resources.
The task of the assessor is also made easier if he can choose alternative sites or areas on the basis of existing land-use and conservation zoning. By extension, the prediction of impacts is greatly facilitated if the environment has already been classified according to relative sensitivity to disturbance or seriousness of potential loss (cf. Bols, 1978; Specht, Roe and Bougton, 1974).1
1 Basic environmental dada of vital importance to EIA can sometimes be assembled for vast and remote areas at a reasonable cost. An example is the Canadian Arctic Ecology Map Series, which identifies key animal habitats and their approximate limits. These maps have proved useful in initial planning and siting of projects. Preliminary maps carry the risk of engendering a false sense of security.
Ultimately, EIA should be seen as a refinement of prior land use and ecological mapping and classification which already incorporate important policy decisions regarding the use of national space and natural resources. It is unrealistic to expect the assessors of individual development projects to make major decisions concerning resource use, such as the decision to leave an entire region unaffected by development. And yet such decisions will be faced by assessors if El, occurs in the absence of a broader policy framework concerning socio-economic development and use of natural resources.
3.3.2 Evaluation of alternatives
The evaluation of alternative project sites or areas and of alternative development methods and scheduling is at the core of detailed EIA. This is because the objective of minimizing negative impacts cannot be achieved, even with the best mitigative measures, if the project takes place in an unusually sensitive setting, or if the development methods used are inherently more destructive than others. The best way to protect the environment is also to avoid impacts, and often this objective can be obtained by the simple expedient of locating the project away from sensitive terrain or sensitive organisms. Similarly, the objective of maximizing beneficial impacts (eg., job creation where most needed, shorter forest roads, better timber) requires the evaluation of alternatives.
A. Definition of Alternatives
Given the goal of minimizing environmental impact, a basic problem in to decide how many alternatives should be considered before there is reasonable assurance that the entire range of alternatives has been explored. In practice, the technical and socio-economic conditions that are indispensable for the viability of a particular project usually restrict the number of choices that can be considered for environmental reasons. The range of alternatives is also sot by constraints of time, funds and data collection in areas that are too large. One criterion that has been cited by US jurisprudence is that "real" alternatives are those that would allow the same project to be realized during approximately the same time and at the same cost as the preferred alternative.
Normally, it is not necessary to consider all possible alternatives and combinations thereof, even in the absence of constraints. This is because most regions can be subdivided into terrain or habitat types of reasonable uniformity. One alternative with in each major type is usually considered by regulatory agencies to be a reasonable evaluation of the geographical-ecological options available.
In developing countries, the alternative of no project at all, which is a legal requirement in some developed countries, may seem unrealistic given the need to raise living standards. The evaluation of the "no-project" alternative takes the form of a statement of the socio-economic benefits foregone, And of a brief summary of the detrimental impacts avoided. An option is not to require a systematic evaluation of this alternative in all cases, but to make clear (either via legislation or environmental regulation) that if the EIR reveals an impact that is socially unacceptable in the case of all geographical alternatives, then the issue of no project at all should be raised and discussed explicitly.
The next task after the definition of the alternatives is to evaluate the relative impact of these alternatives. As noted, in most jurisdictions it is the prerogative of the proponent to state a "preferred" alternative, and to evaluate the other alternatives in terms of variance from the preferred option. By the same token, during the review the "preferred" alternative may be rejected and the review board may exercise its right to focus the comparative analysis on the other alternatives.
It should be stressed at the outset that, regardless of the analytical and predictive methods used, EIRs can only forecast impacts on a probability basis. There is, therefore, morn, to the suggestion to state impacts on a percentage bests of probability of occurrence, as is done in weather and flood peak forecasting. The accuracy of the predictions will depend on the availability of environmental data, on the degree of understanding of the eco-systems present and on the expertise of the assessor(s).
B. Description of the Existing Environment
The point of departure of the prediction of impacts and of the evaluation of alternatives is knowledge of the project areas as they are before development. A description of the existing environment is needed so that reviewers can verify for themselves the accuracy or validity of the impacts predicted in the various alternative areas. Baseline data are also needed in case post-development audits or monitoring of impacts are requested by regulatory agencies. Pre development measurements Or environmental quality, especially in densely settled areas, are also designed to project the proponents in case shore is litigation over the impacts of development, notably in vital sectors such as air and water quality.
The collection of baseline data can become the most expensive and time-consuming part of EIA. In turn, descriptions of the existing (ie., pre-development) environment can make up the bulk of EIRs. Those two tendencies must be guarded against. Rather than improving the quality of EIRs and, hence, of decision making, masses of field data and lengthy descriptions of the environment often detract from the usefulness of these documents. A specific tendency that must be avoided is to include in EIRs exhaustive inventories of the geology, soils and of all plant and animal species in the project area(s). Experience has shown that these accumulations of data tend to become ends unto themselves, thereby displacing in the EIRs the emphasis on socially important impacts and on the choices facing decision makers. As stressed earlier, an effort must be made to produce and use EIRs as decision making tools, otherwise EIA soon loses credibility.
Descriptions of the existing environment should be brief and focused on aspects of the project area or site that are most sensitive to disturbance. For example, a description of the entire fauna is not necessary, only a mention of those species - and their habitats that are sensitive, important and that are potentially threatened by the project. Similarly, the description of the vegetation should provide a brief biogeographic context of the plant life in the project area (eg., area of unusually high species diversity, convergence of dispersal routes, boundary area for major flora, etc.) and thereafter confine itself to the intrinsic scientific and economic value and relative sensitivity of the main floral assemblages to be affected. The geology of the area(s) need not be described in full, but only those aspects that have a bearing on, say, elope stability, groundwater recharge, erodibility of Boils, runnoff or sediment yield.
The possibility or probability of rare or unknown species of plants and animals being present should be discussed explicitly in sub-chapters devoted to the subject. The same applies to other topics of scientific or social value, such as fossiliferous bode likely to be exposed by road construction in the case of geology or mineral springs in the case of hydrology.
The description of the existing environment should rely as much as possible on cartographic, graphic or other visual moans of data presentation. In the tropics, particularly the humid tropics, it can be expected that few published data will be available at suitable scales (eg., geological and soils maps at scales of 1:20000 to 1:50000), that few detailed ground surveys will be possible, and that, therefore, much of the description of the existing environment may consist of aerial photographs and their interpretation. At the moment, air photo-interpretation is probably the most effective way of obtaining environmental data in remote and poorly accessible regions (Poore, 1976b), but other forms of remote sensing are being increasingly wed to this end (Pettinger, 1978; cf. Proceedings of the International Symposia on Remote Sensing of the Environment, Ann Arbor, University of Michigan Environmental Research Institute, particularly from 1977 (vol. 11) on). Interpretation of air photos and satellite imagery has, so far, emphasized the classification of vegetation (Pettinger, 1978; Singh, 1974; Swellengrebel, 1965; Tiwari, 1975), but increasingly remote sensing is being applied to analyses of animal ecology, terrain stability, water quality, watershed condition and other aspects of the environment.
It is suggested that, in the absence of ordinary ground investigations and of direct measurements of environmental parameters, assessors and regulatory agencies reach a consensus as early as possible in the assessment procedure on what constitutes an "adequate" data base given these constraints. For example, if air and water quality cannot be measured, a consensus could be reached on certain categories of quality (eg., poor, intermediate, good) on the basis of easily verifiable criteria such as the presence or absence of potential polluters and environmental indicators (towns of various sizes, specific industries, certain fish populations, absence of algal blooms, etc.).
Descriptions of the existing environment should identify gaps in the data coverage and recommend administrative action needed to fill these gape, if necessary. EIRs should recommend delays in the granting of permits if the gaps are sufficiently serious that they prevent the prediction of impact e in sectors deemed important in a particular context. A case in point might be the suspected presence of rare, endangered or protected species in the project area. By clearly identifying data gaps, Elite serve the important function of focusing regional or national programmes of environmental research and thus of facilitating future EIA.
C. Evaluation of Impacts and Comparison of Alternatives
Once the forestry activities have been identified and the pre-development environments have been described, the next step is to predict the impacts of the former on the latter. As discussed in Section 2.2.2, each jurisdiction must decide whether to require EIRs to identify unmitigated ("raw,) impacts, mitigation (remedial measures) and "residual" impacts (impacts remaining after mitigation) separately, or whether EIRs should discuss only mitigated impacts. The important consideration is to state clearly the type of impacts being discussed and the assumptions that have been made concerning mitigation. Mitigation gains credibility if EIRs can refer to well-tried operational handbooks of environmental protection (cf. Section 1.3.1; Appendix VI). Some reviewers may, in fact, require the filing of such handbooks if the EIR being reviewed discusses mitigated impacts.
The principal methods for evaluating environmental, impacts and for comparing various alternatives are the following:
(1) The impact matrix, which lists actions (logging, log hauling; sawmill operation, etc.) along one axis and the potential environmental modifications along the other; the impact is then recorded in boxes at the interception of the two axes by means of a code (usually a ranking, 1 to 5 or 10) which conveys the assessor's judgment concerning the magnitude and importance of the particular impact; matrices for the various alternatives are then compared.
(2) The overlay (McHarg) technique, whereby transparent maps of the various environmental components (shown in some order of relative sensitivity to disturbance) are superimposed and areas of least or maximum cumulative sensitivity are located; a variation on this technique is to prepare maps showing the same features (say, erodibility of soils or relative density of primates) by mesas of digital values, and to let computers determine areas or corridors of least impact.
(3) The Battelle Environmental Evaluation System, which is the most quantitative and "objective" of the methods listed, as it relies on the transformation of parameter changes (eg., levels of dissolved oxygen, number of peat species, vegetation diversity) into corresponding levels of environmental quality by means of a value function.
(4) The flow chart and accompanying test, which traces the impact of various actions by moans of flow diagrams and arguments from well established premises and casual relationships, and ending with value judgements concerning the magnitude and importance of the impacts predicted.
(5) Computerized simulation modelling of the various ecosystems (usually only sub-systems such as water quality, primary productivity and, at the most, secondary productivity) to be disturbed.
Details concerning those methods and evaluations of their strengths and weaknesses are given by Munn (1979), Teller (1977)1 and by most works on EIA (cf. Annex B). Munn (1979) evaluates the first three methods listed above in terms of capability of the method, replicability of results, level of detail, and of money, time, skilled manpower and other requirements. It is clear that the Battelle method is by far the most refined, but also the most demanding of money, time, skilled manpower and baseline data. None of the methods eliminate, of course, the need to use sound judgment. There is also no substitute for thorough familiarity with and understanding of specific natural systems.
1 In FAO Conservation Guide 1.
In the developing countries, the tendency will probably be to use, at least initially, matrices and "argued" evaluations of impact, which, depending on the skill and experience of the assessor(s), can be adequate. The opinions of seasoned game wardens on animal behaviour in disturbed habitats or the views of senior highway engineers on the erodibility of certain soils are often the best bases for impact prediction. The quality of impact predictions, whether in the developing world or elsewhere, has often little to do with the sophistication of the methods used.
However, impacts should be quantified wherever possible in order to facilitate comparisons and choices. Quantification in many oases may moan only relative rankings of magnitude or importance. In the effort to quantify environmental parameters (slope angles, sediment loads, areas denuded, numbers of animals, etc.), the tendency to overlook important intangibles such as religious values, traditional beliefs, aesthetics, or scientific value must be guarded against.
In general EIRs must stress the importance to society of the various impacts predicted. For example, it is not enough to record the potential lose of X number of species. This loss must be related to the regional diversity of the flora or fauna, to the scientific significance of the species involved, to the importance of the species within particular ecosystems and to the role that the species might play in the local culture or subsistence economy. Similarly, whenever the lose of individuals of one species is predicted, this foes must be related in some way to the total population of that species and its future viability.
Assigning importance ratings is, of course, the most difficult aspect of EIA next to the prediction of impacts because of the subjectivity involved. On the other hand, experience has shown that different assessors tend to assign remarkably similar importance ratings to the same impacts, despite different professional biases or vested interests. Thus, to give a simple example, both botanists and wildlife biologists assign a higher importance rating to the destruction of a bird nesting ground than to the removal of an unexceptional timber stand of the same size. In a semi-arid region, however, moat assessors would probably rate the removal of a stand of timber as a more important impact than many forms of impact on the fauna. These examples point again to the need to have experienced assessors, with a well developed sense of local priorities, judge the importance of impacts a particular setting.
One technique that can be used to arrive at a consensus on the importance of various impacts is the so-galled "Delphi method" (Munn, 1979). This technique consists of the interrogation of knowledgeable persons ("oracles"), including members of the general public, concerning their views on subjective matters. The participants are interrogated separately in order to avoid mutual influence. The results can then be averaged.
In comparing alternatives, negative and positive impact ratings can be added. However, numbers assist in decision making and are not a substitute for judgement. For example, in the case of a particular alternative, a greater total of beneficial impacts does not necessarily offset a greater total negative impact. Despite a concomitant increase in benefits, the greater negative impact incurred with one particular location may exceed the threshold of social acceptability.
Each case must be judged on its own merits. Fewer benefits coupled with fewer detrimental impacts may be preferable to more benefits but also greater total negative impact. A relatively small negative impact may also acquire a different significance if it is examined in relation to the cumulative impact of several projects in a particular region. In general, a "lesser" adverse impact is not necessarily an "acceptable" impact; this is the reason why some jurisdictions insist on the evaluation of the alternative of no project at all.
The evaluation of alternatives concludes with a statement concerning the alternative of least environmental impact. This alternative may or may not be the alternative preferred by the proponent. In those jurisdictions where the EIR is prepared by the regulatory agency, the reconciliation between the alternative of least impact and that preferred by the proponent may have to occur before the reviewer(s) or, failing that, at the ministerial or political level. In an EIR prepared by the proponent, the latter may add a paragraph that argues the acceptance of his "preferred" alternative over the alternative of least impact if the two differ. This argument may then be accepted or rejected by the reviewer(s) or higher political authority.
Regardless of the procedure adopted, the tendency to produce EIRs in which the "preferred" alternative always coincides with the alternative of least environmental impact should be avoided. A discrepancy between the two does not necessarily mean that the proponent's "preferred" alternative will not be approved. This discrepancy may serve, however, to raise important issues of resource management, and thus to stimulate a useful discussion of environmentally sound development.
As noted earlier, the evaluation of alternatives is at the core of formal EIRs. It is the section of the document that is of greatest interest to decision makers and the public alike. The choices available should be presented clearly. Maximum use should be made of graphic or other visual presentation of data and conclusions. The language should be simple and clear. At the same time, since the EIR is also designed to alert the specialist to problems of impact prediction (insufficient data, poor understanding of ecosystems, ignorance concerning the recovery of disturbed habitats, etc.), discussions of complex scientific issues should not be omitted, but included in appendixes.
3.3.3 Mitigation, phased analysis and monitoring
Unless mitigation. impacts (cf. Sections 2.2.2, 3.3.2 C), separate chapter of the EIR should discuss the reduction of the impacts by means of preventive or remedial measures. As stressed earlier, EIRs should not give operational details of these measures, but should refer to separate handbooks or guidelines of environmental protection (cf. Appendix VI). This chapter on mitigation should end with a summary chart of mitigated impacts, that is those impacts that are unavoidable ("residual").
The EIR should identify impacts for which mitigation is unknown or poorly developed. Similarly, it should stress remedial measures that are unprecedented or specific to a particular project. The EIR should also recommend delays in project approval if it is judged that time is needed to devise adequate environmental protection (eg., passing legislation to control access, poaching illegal felling, or to require tree screens along streams).
The EIR should recommend revisions of the project design or phased environmental analyses during development (cf. Fig. 1, Option 4A) if it is deemed that environmental protection will profit from them Similarly, the EIR should recommend post-development audits (documentation of impacts as they actually happened) or monitoring of long-term impacts or recovery from impacts if it is likely that useful new data will be made available in this manner. Monitoring may be needed to decide at a later date whether new or additional remedial measures are necessary
Audits and monitoring particularly useful in the humid tropics where the functioning of ecosystems is poorly understood. Audits may also yield data of great economic value, especially concerning the regeneration of timber species.
It is incumbent on the EIR to recommend indicators to be used for audits or monitoring. Among such impact indicators may be numbers of breeding pairs, return of displaced animals, regeneration of selected species; nitrogen levels in soils, formation of erosion gullies or landslips rates of incidence of diseases, baseflow in the dry season, storm hydrographs, water levels in wells, shifting cultivation as surveyed aerially at specified intervals, growth of sediment deltas in reservoirs and various socio-economic indicators such as unemployment or disposable income.
3.3.4 Agencies, individual and literature consulted
The EIR should list the regulatory and conservation agencies, scientific establishments, individual scientists, local leaders and the literature consulted If consultations with the public were held, they and their outcome should be mentioned.
This requirement serves to remind authors of EIRs that assessment benefits from continuous consultation, not only because of the data and opinions that can be assembled, but also to avoid last minute confrontations and disagreements that could jeopardize an otherwise acceptable project. Because of the large subjective element in EIA, it is also essential to build a consensus among assessors, the public, regulatory agencies and the scientific community on important policy issues before the EIR reaches the formal review stage. Little is gained from the discovery, at the review stage, that fundamental disagreements exist on the relative importance of impacts or on the alternative locations for the project. In general, a balance must be struck between lack of consultation, which can lead to extreme adversary positions, or too much agreement and compromise before the review of the EIR, which can lead to an undesirable blurring of both environmental and development issues.
An account of the consultation that has taken place during assessment is also useful to independent reviewers, who need to know how many issues of impact and mitigation on have already been discussed and resolved with local residents and the regulatory agencies.