Letter to the editor

As the recipient of IAIA’s Lifetime Achievement Award for 2017, I was asked to make a few remarks at the annual meeting in Montreal which I am repeating here for your readers.

In looking back on my life as an environmental impact assessment practitioner, a number of stories come to mind which illustrate the importance of various issues associated with EIA. I would like to relate three of them here.

The first story dates from the early 1980s when I was working in the Office of Federal Activities of the US Environmental Protection Agency in Washington, DC. My job was to review the environmental impact statements prepared by federal agencies on actions ‘significantly affecting the quality of the human environment.’ One of the most remarkable EISs I reviewed during that time was one prepared by the US Drug Enforcement Administration (DEA) on the use of a pesticide called paraquat to destroy marijuana fields in Central American countries. Paraquat is highly toxic to mammals, including humans, potentially leading to acute respiratory distress syndrome (ARDS).

The only impact addressed in the draft EIS on the pesticide use program was the possible health effects of paraquat-sprayed marijuana on American users which might have access to any of the plants making their way into the US. The impact was not judged to be significant and, as a mitigation measure, it was pointed out that, because paraquat is water soluble, any potential negative health effects from paraquat-sprayed cannabis could be mitigated by smoking it in a water pipe.

Shortly after the EIS had been published I noticed its cover page prominently displayed in the window of shop near Georgetown University. The accompanying sign asked: ‘Worried that your pot might be poisoned by a pesticide? A US government environmental report has found there is no danger if you smoke it in a water pipe. Come in and take a look at our selection of pipes!’

A quick conversation with the shop owner revealed that his business was booming.

Lesson Learned: Environmental Impact Assessment can provide economic benefits.

The second story dates from the mid 1990s when I was employed as an environmental specialist at the European Bank for Reconstruction and Development (EBRD). A request had been made by the government of Kazakhstan for a loan to fund the rehabilitation of the Port of Aktau on the Caspian Sea. The port, which included both a number of dry cargo berths and a breakwater topped with an oil pipeline, was in danger of being inundated due to the rising sea level of the Caspian. My task was to screen the project (as A, B, or C) to determine the level and scope of assessment needed.

Given the lack of baseline data and general environmental information about the site, I decided to travel to Aktau to conduct an ‘Initial Environmental Investigation (IEE).’ The purpose of the IEE was to conduct a site visit and speak with as many authorities and affected parties as possible about the potential environmental impacts associated with the project. As my Russian language skills were almost non-existent, I hired a translator to assist me with interviews during my stay.

My translator, a tall, striking woman with light blonde hair, flashing eyes, dark red lips and fingernails, and wearing a full length sable coat and hat, met me at the airport. ‘Good morning,’ she belted out, ‘I am your translator, Olga Petrovna. Welcome to Aktau!’ While hustling me into a waiting van, she proceeded to tell me a lengthy tale about a KGB agent interrogating an eskimo and who needed the services of someone like herself. It was a chilling account which made clear the importance of trusting someone like Olga in a place like Aktau…but that’s another story.

Aktau itself was one of the most desolate places I have ever visited. Founded in the late 1950s as a camp for workers in the oil industry, it was also the site of a nuclear power station. The town itself seemed to be made up solely of identical, grey apartment and office blocks in various stages of disrepair and dilapidation. The streets had no names, instead addresses consisted of three numbers: the district number, the building number, and the apartment number. There were no hotels. I was lodged in a small, sparsely furnished apartment near the port. There was no sign of vegetation. The month was January – sub zero temperatures, wind, and freezing rain.

Over the course of my visit (and with Olga Petrovna continually by my side), I interviewed numerous representatives of city and port administrations, planning commissions, environmental authorities, and local inhabitants. All were unanimous in the support for a project which would raise the dry cargo berths and reinforce the breakwater. Many pointed out that not only did the proposed project not have any negative environmental consequences, but that it would provide environmental benefits by repairing the breakwater and thus help to prevent future oil spills. Proceed at full speed was the advice.

Concluding that the project did not need to be screened as an A-level project, I began to prepare for my departure. In saying goodbye to Olga Petrovna she expressed the hope that I would return to Aktau and at a different time of year. When I asked what time she would propose, she answered: ‘In Spring for not only for better weather but in order to see the baby seals.’ ‘Seals?’ I replied.

‘Yes’ replied Olga. ‘These are special seals, unique to the Caspian and exist nowhere else. They spend the winter on the southern shores of the Sea in Iran but come to Aktau in the Spring to have their babies. This port is their nursery.’

Suddenly Aktau Port became an A-level project with possible impact on an endangered species as a focus of investigation.

Lesson learned: extensive consultation with the public at large (including interpreters) is often necessary to reveal the existence of major environmental impacts which might otherwise not come to light.

The third story dates from the late 1980s while I was working for the Dutch Ministry of Environment. I had been hired to coordinate a UN Economic Commission for Europe (UNECE) Task Force on the ‘Application of Environmental Impact Assessment of Highways and Dams’ which was led and funded by the Dutch government. The purpose of the Task Force was to determine ‘what had worked where, when and why’ in applying formal or informal EIA procedures to project planning and examine a variety of case studies in the United States, Canada, Germany, the Netherlands, Finland, and Norway.

One of the main research questions related to the use of methods, particularly formalized, quantitative methods for predicting impacts and comparing project alternatives such as the Leopold Matrix, a system for the analysis and numerical weighting of impacts involving over 8000 possible interactions.

The conclusions and recommendations of the task force are as relevant today as they were 30 years ago. The attention to monitoring is perhaps the most cogent example:

Conclusion: ‘The provision for, and implementation of, monitoring programmes appears to be one of the most neglected areas in EIA.’

Recommendation: ‘A monitoring strategy should be developed early in EIA to allow baseline data collected during the EIA process to be made comparable with monitoring data collected after the project proceeds. Post project monitoring would also allow any unpredicted effects to be identified and hence mitigated.’

But perhaps the most significant finding and one which I find has withstood the test of time, related to question of methods. It was that the lack of evidence that formalized, quantitative methods were actually used and that ‘best professional judgement’ and ‘previous experience’ most often formed the basis for assessing the significance of environmental impacts.

Lesson learned: for a successful EIA, ensure that the best professionals with ample previous experience are hired to perform the job.

And where does one find those professionals? Why at the IAIA of course – the international organization that continues to educate and inspire practitioners like myself.

Bill Kennedy

Disclosure statement

No potential conflict of interest was reported by the author.