Evaluating environmental and social impact assessment in developing countries

In their book, Momtaz and Kabir evaluate the effectiveness of EIA systems in Bangladesh within the context of an empirically ‘integrated holistic framework’. The basic elements of their model are the presence and status of impact assessment as a planning and decision-making tool in legislation and government planning for development; it refers to the quality of impact statements such as the access to agencies or any impact assessor to professionals and their skills, the role of community consultation; and, importantly, measuring the institutional capabilities that regulatory or development agencies have for monitoring and mitigating impacts as they accumulate over time. The book, in its holistic and interdisciplinary approach to EIA, emphasizes the importance of institutional capabilities, as access to knowledge and research as well as to professionals highly trained in the biophysical, social and economic sciences, which are fundamental resources facilitating quality impact assessments.

The book stresses that institutional effectiveness over time contributes to not only the temporal quality of ‘holistic’ impact assessment, but also the necessity of long-term monitoring of development projects. Whereas the former is dependent upon access to qualified professionals working together and their research teams bridging disciplinary chauvinism and swagger, the latter is dependent upon long-term institutional support and political legitimacy so that project monitoring continues throughout the life of a project and beyond. We used to speak of the so-called ‘technical’ and ‘political’ models of impact assessment and of course we knew then and now that these processes are, in practice, inseparable. As they note, ‘post EIS follow-up’ is often neglected in developing countries as it is, similarly, in the industrially advanced countries and, I would add, that, in both, effective follow-up is based upon levels of institutional capacity and institutional legitimacy.

Chapter 7 applies their model to three large-scale rural development projects finding that the quality of the original impact assessments, including mitigation procedures, varied across the cases. Based on site visits and community analyses, the authors examined the quality of community consultations that took place in the early stage of the project cases. The authors also conducted environmental auditing of these projects to determine the differences between EIA predictions and actual environmental impacts as well as the mitigation measures on site to date. The projects fulfilled some of their environmental monitoring and mitigation commitments while failing to do some of the others. Post-EIA auditing has been, as they point out, the weakest link in the EIA process. These findings fit with other studies showing that due to institutional and public impatience with continuing investigations, mitigation procedures are often neglected or only partially implemented. Mitigation is critical to the EIA process as is an ongoing analysis of ‘quality’, as they define it, not just to check on the accuracy of predictions and whether mitigation is occurring or working, but also to define and measure impacts cumulatively.

Although their study interests are on Bangladesh, the model is generalizable, with care, to both developing and industrially developed countries. Its approach to project evaluation is, importantly, sensitive to spatial inequalities and uneven development at local community and regional scales. This is a valuable tool for ‘post EIS’ follow-ups, but as they correctly argue, much more is needed to protect the environment and the institutional integrity of local communities than ‘good quality’ EISs. Impact assessment will generally be effective, temporally and over time, when they are conducted in the context of supportive statutory bodies committed to promoting and enforcing laws and policies that are designed to achieve environmental and social justice.

Academic researchers and project planners should read this book along with theory and research on social power, legitimacy and trust. A critical chapter on social and cultural institutions, institutional inertia and ‘deep-structure’ influences on how government and community participants think and act would have been a welcome addition. In fact, their data could be analysed in an institutional framework and contribute significantly to our knowledge in this important area. They more than make up for this limitation by discussing the importance of qualified professionals for good-quality impact assessments conducted either by government, other public bodies or private organizations. As they suggest, the variable quality of the impact assessments they analysed was due to a number of factors. A lack of baseline data was an important contributor to relative failure, but also time limitations, scarce funds and poorly organized EIA teams. Outstanding among these factors was the commercial and proprietary interests of consultants and advocates. Their study fits with the too common findings in development studies that independent professionals and consulting firms hired by government agencies, and private developers are there less for their advice than to establish legitimacy.

It is important that we remind ourselves that old, culturally institutionalized ways of thinking and acting are seductive and the challenge to development planners and decision-makers, local communities and to professionals, including social and environmental assessors, is, following Rorty (1989, xxiii), to ‘be more than the enactor of a previously written script’. That said, the book is written with a careful reading of their field's literature and years of field experience in Bangladesh, lending considerable credibility to their conceptual and practical conclusions. It contributes strongly to the impact assessment and development literature. The book demonstrates the depth and diversity of their research and writing making it essential reading for university researchers, planners, independent professionals and institutional decision-makers and partners (World Bank, Asian Development Bank, NGOs) needing to evaluate the success of their development projects. I recommend it strongly.