Is impact assessment ensuring proper prediction and assessment of the environmental, economic, and social impacts of projects – how to reduce bias?

A study by the Ecological Society of Australia (Driscoll et al. 2020) found that about one third of industry-employed ecologists and conservation scientists said they had experienced undue modification of their work. The most common suppression concerned the plight of threatened species with 56% of people working in this area reporting that they felt restricted in what they could say. Don Driscoll, the lead author and past president of the Ecological Society of Australia, said that: ‘In reality, these findings may be the tip of the iceberg’ (Guardian 2020). ‘It reflects the type of corruption that’s going on in the system.’

In the opening plenary for the 2019 IAIA conference in Brisbane, environmental lawyer David Morris (2019) addressed the conference theme of ‘Evolution or revolution: where next for impact assessment’. He described the impact assessment process in the Northern Territory in Australia as a system out of balance, which he considered had become a tool of powerful political and economic interests – and in effect just a rubber stamp. He contrasts the process that led to the approval of the environmentally damaging McArthur Zinc mine in Northern Territory with the New South Wales Social Impact Assessment Guidelines (Parsons et al. 2019) which led to a landmark decision to reject the Rocky Hill mine after consideration of climate change, indigenous views and aspirations, loss of sense of place and distributed inequity.

A review of 25 years of IA practice in the United Kingdom and Netherlands (Arts et al. 2012) concluded that, although it appears that in the Netherlands and the UK, EIA is performing quite well, EIA currently does not appear to fully provide an effective platform for an open and creative discussion about plans, programmes, and projects.

Strategic Environmental Assessments (SEAs) were touted as a remedy to the woes of IA, specifically by better dealing with cumulative impacts and uncertainty (Banhalmi-Zakar et al. 2018). However, Lobos and Partidario (2014) have found that many SEAs have the same ethical problems as impact assessments, in that they are often being prepared by industry technical specialists funded by the project developers.

Some large environmental consulting firms that are providing environmental and social consulting services to projects across a broad range of technical services are also providing auditing services to the same clients. This crossover of consulting and auditing services could lead to accusations of unethical behaviour. At face value, it is an obvious conflict of interest.

What are proposed solutions to bias in IA?

The study by the Ecological Society of Australia (Driscoll et al. 2020) presented various processes for achieving independent scientific input into public and policy debate including an independent authority responsible for environmental research related to environmental assessment, independent peer review of reports (such as the NCEA in the Dutch IA system), and open, timely publication, and archiving of data, reports, and decisions (Singh et al. 2018: Westwood et al. 2019). They also suggested that professional societies should defend scientists and foster a culture that supports open communication and document cases of suppression to demonstrate the need for reform.

Don Driscoll et al. (2020) highlighted the need for an independent watchdog such as a national Environmental Protection Authority to assess development proposals and determine whether the projects should go ahead. ‘It’s vital our environmental assessments are changed so that the people doing the damage are not employing the scientists doing the assessment of the damage to the environment.’

David Morris (2019) of the Environmental Defenders Office in New South Wales proposed four solutions to address this imbalance: an independent panel of consultants that would be randomly allocated to projects in order to minimize collaboration, consultants signing a statement of compliance against best practice (with censure measures), third party merits reviews, and mandatory Social Impact Assessment to place cultural considerations and the independent voices of the affected community at the heart of impact assessment.

In accounting practice, the Financial Reporting Council (FRC) in the UK has told the big four accountancy firms to fence off their auditing operations as part of a drive to improve oversight of corporate finances in the wake of high-profile collapses such as Carillion and BHS (Wall Street Journal 2020). They include a provision that auditors be protected from influence that could come from the rest of the firm to reduce audit quality.

Independence and the role of IAIA

The IAIA has a Code of Conduct (IAIA 2021) which commits members to conduct professional activities with integrity, honesty and to refuse to provide advice when this might bias the analysis or omit or distort facts to arrive at a predetermined finding or result. However, while the IAIA does provide opportunities for the open discussion of ethical dilemmas at its conferences and journal it lacks a clear organizational procedure for addressing code violations and does not have the necessary support to monitor compliance ((Vanclay et al. 2013). An issue for discussion therefore is whether IAIA should play a more active role in preventing or addressing code violations and if so, how this may be organised in practice.

In the code of conduct the issue of ‘independence’ of IA practitioners and reviewers is one of the central themes. Many practitioners claim they are independent, but little consensus exists on what this then actually means. This clearly erodes the validity of the concept. A second issue for discussion therefore would be whether IAIA has a role in enhancing independence in IA? If so, would a professional standard be part of that? And if yes, are the suggested building blocks by Verheem (2020) a good starting point for this standard?