Letter to the Editor: “Talking to the Experts: Can we improve the ESIA Process?”

Ian Campbell
Friday, March 22, 2013

Having worked as a river ecologist for over 40 years, including a number of years working in the lower Mekong and PNG, I was interested to reading your articles in the ESIA process. I have worked as a consultant conducting ESIA projects, in regulatory agencies evaluating ESIA reports and in academia reviewing reports for agencies.

While I share the concern of the members of your panel with the poor quality of much of the technical work included in ESIA reports, I strongly disagree with their suggestion that impact assessments should be conducted by accredited independent third-party evaluators. It has proved to be extremely difficult to establish meaningful accreditation systems for environmental scientists. The Ecological Society of America has one that is reasonably rigorous for ecologists, but a number of other professional societies have struggled with, and abandoned, the concept as largely unworkable.  Some others have adopted systems which rely largely on favourable references from clients.  Presumably the consultants of whom the experts are so critical would not have trouble in obtaining good references from their clients.

The problem is that environmental and social sciences encompassed in ESIA procedures are very broad, so establishing appropriate qualifications and criteria for certification, and a fair de-certification process, are extremely difficult. A certification process without a de-certification system would be meaningless.  

It does not seem to me that there is a problem with the project proponent being required to hire, and pay for, the consultants to conduct the studies. That is consistent with a “polluter pays” policy.  The major problem is that there is inadequate independent technical review, or peer review, of the work that is done. Where there is a rigorous review process managed by government regulatory agencies the project proponents quickly learn that there is no point in producing inadequate or incomplete ESIA reports because they will either be rejected totally or required to be revised until they are adequate. This has been the case in a number of national and subnational jurisdictions in my experience.  It is not a perfect system, because where governments see political (or occasionally financial) advantages in projects they will sometimes push projects through regardless of the social and environmental consequences, but it does improve the quality of the ESIA work being conducted.

Lack of peer review of consultants’ reports is a significant problem for the environmental “industry” in general. Many of the organizations commissioning reports are simply unaware of the need for peer review to ensure quality in science. Even highly competent consultants sometimes make mistakes, and since consultancy contracts are frequently awarded largely on price, many consultancies rely heavily on the work of inexperienced recent graduates.  In other cases consultants may work completely outside their field of expertise. An appropriate review process would ensure that proponents paid greater attention to hiring appropriately qualified consultants.

Regrettably, neither the World Bank nor the Asian Development Bank, who should be setting and example, routinely conduct independent technical reviews of ESIA documents or other technical reports.  It would have been most interesting to have seen such a review of the Nam Theun 2 documentation.

The problem of a lack of review is more acute in many undeveloped countries, where the agencies responsible for environmental approvals often not only have a very low level internal  capacity to evaluate ESIA reports, but also lack the capacity to implement an independent technical review. That is an area where donor agencies and NGOs  may be able to assist, both in raising awareness in government agencies of the need for reviews, suggesting potentially appropriate reviewers and in some cases providing funding support for the process. Donor agencies should also require such reviews.