Investigating the effectiveness of mandatory integration of health impact assessment within environmental impact assessment (EIA): a case study of Thailand

Figures & data

Table 1. Power plant project development mandatorily requiring EHIA in Thailand.

Types of fuels used in thermal power plant projects requiring EHIA	Power generation capacity (MW)	Practice regarding regulatory
(1) Coal	≥ 100	EHIA required to submit for construction approval/or project operation permit any scale
(2) Biomass	≥ 150
(3) Natural gas operated by combined cycle or cogeneration system	≥ 3000
(4) Nuclear

Source: adapted from Natural Resource and Environment Ministerial Notification Re: specification of types, scales, and regulations for projects which may cause severe effects on health, environment and natural resources B.E. 2553 (2010).

Figure 1. Decision-making flows of EHIA approval and project development for power plant projects proposed by Electricity Generation Authority of Thailand (EGAT).

Source: adapted based on Natural Resource and Environment Ministerial Notification (2009), Office of Natural Resources and Environment Policy and Planning (2013, p. 45) and The Prime Minister’s Office (2010).

Table 2. Completed EGAT EHIAs approved by ONEP and processed by ICEH and regulator (ERC).

Table 3. Relevant documents of the four power plant EHIA cases and key informants as sources of data collected in this study.

Sources of data	Power plant projects	No. of reports by title	Source of data	Data collection methods	Remarks
EHIA report approved by ONEP	Case 1: Bang Pakong combined cycle power plant block 5	2	ICEH website/ERC website	Documentary review
Power plant project EHIA full & summary reports of 4 power plant EHIA cases	Case 2: Mae Moh power plant unit 4–7 replacement	2		ICEH (2013, 2014, 2016a, 2016b), SECOT Co.Ltd 2013, DIW and ERC Stakeholder Public Consultation Committee (2014), ERC Stakeholder Public Consultation Committee (2014), Team Consulting Engineering and Management Co. Ltd (2014), ERC Stakeholder Public Consultation Committee (2016a, 2016b), SECOT Co. (2016a, 2016b)	Views from affected community members were investigated based on different sources of public consultation summary reports provided by EHIA consultant(s), ICEH and regulatory authority (5 times of PP in total conducted in each one particular project)
(main reports + summary reports)	Case 3: South Bangkok (Phra Nakorn Tai) power plant replacement phase 1	2
	Case 4: Bang Pakong combined cycle power plant unit 1–2 replacement	2
Support statutory consultation by ICEH	Case 1: Bang Pakong combined cycle power plant block 5	1
ICEH advisory comment reports of 4 power plant EHIA cases	Case 2: Mae Moh power plant unit 4–7 replacement	1
	Case 3: South Bangkok (Phra Nakorn Tai) power plant replacement phase 1	1
	Case 4: Bang Pakong combined cycle power plant unit 1–2 replacement	1
Approval process by ERC	Case 1: Bang Pakong combined cycle power plant block 5	1	DIW website
Public hearing summary reports	Case 2: Mae Moh power plant unit 4–7 replacement	1
of 4 power plant EHIA cases	Case 3: South Bangkok (Phra Nakorn Tai) power plant replacement phase 1	1	ERC website
	Case 4: Bang Pakong combined cycle power plant unit 1–2 replacement	1
Key informants:
EGAT representative				Semi-structured & in-	Official request letters were sent to relevant organisations & consultants. Assigned to respond to the interviews later on. However, not all expected participants took part according to their time availability
Statutory consultation representatives				depth interviews
EIA/EHIA practitioners
Health authority representatives
ICEH representative
Regulator representatives

Table 4. Key informants having been involved with power plant EHIA cases contacted and interviewed.

Group	Key informants	Letters sent	Interviewed	Code
1	Project developer	1	1	EGATrep #1
2	EHIA practitioners/ consultants including those conducting EGAT’s EHIA	8	4	Practitioner #1
				Practitioner #2
				Practitioner #3
				Practitioner #4
3	Government organisations
	Environment authority	3	2	GOrg #1, GOrg #2
	Health authority	1	2	GOrg #3, GOrg #4
4	Independent organisation	1	1	ICEHrep #1
5	Non-government organisations/	1	1	NGO #1
6	Regulator	1	2	Reg #1, Reg #2
	Total	17	13

Table 5. EHIA effectiveness analytical framework.

Procedural effectiveness criteria	Substantive effectiveness criteria
P1. Relevant policy framework and procedures for EHIA process – Existence of national plan on environment and health, regulations or guidelines or standard performance for EHIA, and licensing.	S1. Regulatory framework on implementing EHIA in decision-making.
P2. Institutional roles, collaborations & infrastructure – Existing environmental monitoring network, disease surveillance network, and allocated roles of relevant authorities in impact assessment process.	S2. Incorporation of proposed changes – most or all proposals for changes or additions to the draft emanating from the EHIA were taken into account in the final version of the project/ or programme related to project development.
P3. Integrating EHIA in planning process	S3. Informed decision-making – the use of mandatory documents as part of the EHIA process, with continuous dialogue between the parties involved in the process of informed decisions on the final version of project development
P4. Identification of financial funds for EHIA practice	S4. Close collaboration – there was communication and a high level of collaboration between those producing the EHIA, and project developer.
P5. Involvement of stakeholders in the process.	S5. Parallel development – the EHIA and the project/ programme developed alongside one other with considerable cross-cutting between the processes.
P6. Capacity of EHIA in presenting as a sound and clear, understandable evidence for decision-making process with validity of predictions, argumentation, and understandability	S6. Early start – the EHIA process was initiated at the very first stages of project development.
P7. Delivering the findings of report to participating stakeholders	S7. Institutional and other benefits – there is strong evidence of better department relations, development of otherwise absent expertise, learning, new partnerships and better public-private-voluntary sector communication as a result of EHIA when implementing in decision-making.
P8. Time enforcement for EHIA process	S8. Successful statutory consultation – the statutory consultation bodies had a fair opportunity to contribute their roles, and their views/comments were taken on board.
	S9. Successful public consultation – the public consultation bodies had a fair opportunity to contribute and their views and comments were taken on board.
	S10. Satisfactory/ understandability/Comments in using EHIA in decision-making process
Transactive effectiveness criteria	Normative effectiveness criteria
T1. Time – EHIA was carried out within a reasonable time frame without undue delay or within a very short time period (as compared to old ex-ante mechanism, where applicable).	N1. Adjustment of relevant policy framework concerning the normative goal achieved in term of changes of views.
T2. Financial resources – carrying out the EHIA did not entail excessive spending	N2. Learning process, perception, and lesson learnt from EHIA.
T3. Skills – the acquiring of skills and personnel required for the EHIA did not contribute a big burden and these were easily accessible.	N3. Development or changes in relevant institutional policies and policy choices
T4. Specification of roles – responsibilities were clearly defined and allocated and tasks were undertaken by the most appropriate subjects.	N4. Improvement of health outcomes and quality of life

Sources: adapted for this paper based on framework developed by Chanchitpricha and Bond (2013, 2015).

Table 6. Effectiveness overview of power plant EHIAs based on documentary analysis and interviews.

Table

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