WHO NEEDS EcIA GUIDELINES?
Anyone who is a practising ecologist should be up to date with contemporary best practice for ecological impact assessment. This includes people whose work is used to:
- Influence policy development or decision-making about development (including consultants, private company environmental managers, academic research scientists and government decision-makers); or
- Makes decisions that affect the integrity of the landscape, even if these are done with the purpose of environmental enhancement (land / park managers, conservation groups etc);
- A working knowledge of EcIA is recommended for anyone else who places themselves in a position of any authority to comment on the work of others involved in practice.
To introduce a consistent and agreeable framework for ecological work in practice, particularly where this is done in conjunction with statutory EIA and the principles of sustainable development (and therefore, biodiversity conservation). This should benefit those who work in ecological practice, those who commission such work and those that depend on its outcomes to maintain a healthy functioning ecosystem.
To develop a professional reference document that facilitates the design, implementation and ongoing development of Ecological Impact Assessment best practice.
To set out the latest and internationally-recognised scientific methods available to ecological practitioners, for creating biodiversity outcomes in their work.
Guidelines (if properly implemented) can help remove some of the uncertainty for developers and provide consultants with a foundation on which to establish reliable impact assessment without costing the client more...in most cases, it is likely to cost less if it is done properly. Guidelines apply to anyone and everyone involved in ecological work relating to sustainable development. This includes government, academia, consultants and land managers.
- There is a very significant lack of biodiversity evaluation criteria published by government (e.g. the lack of Biodiversity Action Plans). This seriously undermines the EIA process. Values need to be determined up front in an EIA and in order to limit uncertainty, need to be simple to understand.
- Too many generalised statements of impacts are made in reports with little evidence or logic leading up to this. Lack of referencing and evidence.
- Actual size of consultant reports is often too large. The need to produce a publicly consumable document is lost in the pursuit of a 'scientific' document. Scientific integrity is important but so also is the manner in which it is presented.
- More emphasis needs to be placed on the integration of ecology with social and economic issues (triple-bottom-lining). All too often ecological investigations are isolated when they should be integrated.
- Information gathered by consultants is a wasted resource as it is not collected and used as evidence for other EIAs. Information is not made freely available. Monitoring is rarely done and when it is, it may not be done to evaluate changes against goals and management requirements.
- Confidence in assessment of impacts is not adequately presented.
- Health and safety aspects controlling outdoor work often limits the ability to do the work.
- Control by Animal Ethics regulations hampers implementation of work. Often inappropriate to field ecology and the objectives of EIA.
Certification is extremely important and relevant to the profession. However, it must not only be perceived to control standards but demonstrate a real commitment to controlling the behaviour of its members.
- Certification needs to guarantee a level of audit and review of members, and respond to concerns about members.
- Certification processes ought to be implemented by the profession and, if necessary, endorsed by Government.
EISs are often too big, to the detriment of developers but also causing limitations on appropriate scientific investigation of impacts. A much greater emphasis must be placed on limiting the bounds of EIAs to what is relevant. This means more involvement of consultant expertise in the development of project scopes, in particular Terms of Reference.
- Little emphasis is given to considering the relevance of content up front. This results in an array of unnecessary investigation, coupled with a lack of emphasis on truly necessary work.
- Terms of Reference are often broad in nature, so leave a lot of room for investigation but the problem is that this fails to appropriately limit scope.
- Terms of Reference are very often interpreted in such a way as to force consultants from a position of 'best practice' to minimum defensible methods.
- EISs are full of enormous amounts of background information on existing conditions but relatively little skill and time is spent on the actual process of impact assessment - This is one of the most important points. The process of actual impact assessment (in the context of effects on the environment) is all but lost.
Despite the growing sophistication of ecological methods, basic skills such as field natural history and taxonomy are not being taught. There are also a range of other interpersonal skills that are absent from the training of ecologists as 'scientists', which can greatly limit their career potential.
- There is an overall lack of training and funding in field ecology and taxonomy.
- Limited training and funding in taxonomy.
- There was a suggestion that internships may help.
Property developers were particularly concerned about the lack of expertise in government. Lack of symmetry in skills between the consultants and decision-makers may threaten the implementation of appropriate best practice and result in poor outcomes.
- There is too much trade-off between professional judgement and prescriptive requirements. This very often limits the ability to creatively engineer best policy outcomes tailored to a situation.
- There is too much tension between consultants and government.
- Government are too easily influenced by changing political situations. Particularly in the absence of well thought-out terms of reference (see above) approaches can change regularly, leading to gross uncertainty in the process.
- Legislation does not provide the full scope of an EIA.
- Policy often leaps to the implementation of mitigation without first ascertaining the level of impact.
- A couple of examples were raised where clients were punished by government rather than commended. This possibly reflects a lack of foresight about how EcIA works and how to achieve objectives.
- Policy misintervention can lead to serious shortfalls. For example, both biobanking and habitat hectare schemes are vulnerable to failure. Independent guidelines are needed to ensure that critical assumptions of the methods are addressed and should apply as much to policy-makers and decision-makers as consultants.