Integrating Climate Change Considerations in Environmental Impact Assessment

Planners and regulators today are not addressing the impacts of Climate Change (CC) adequately in the future plans. This is not just the case with the developing countries but with the developed countries as well. There are very few examples available where you see CC is reflected in policies, plans and project designs. CC is more talked on the vulnerability.

The level of progress in integrating CC considerations in EIA varies considerably. Countries like Netherlands, Canada and Australia have been the pioneers in implementing incorporation of CC in EIA. While Netherlands includes CC through a Strategic Environmental Assessment (SEA), Canada and Australia have taken the route towards CC integration through project level EIAs. The European Commission, in its directive on the assessment of the effects of certain public and private projects on the environment, aims to reflect CC-related concerns.

When Indian Ministry of Environment & Forests added Climate Change to its title, I was hoping to see integration of Climate Change in EIA.  Unfortunately, I don’t get to see any traction in this direction. There is a need to address this issue by suitably modifying the existing EIA Notification.

Although CC related concerns and understanding are growing, incorporation of CC in the EIA process has not seen an acceptance as expected. Project developers in countries like Canada, a pioneer in this area, believe that not much climate related information is available to analyze the impacts of climate change on the projects. Besides, data availability and expertise on CC modeling is still an issue.

International Association of Impact Assessment surveyed the Australian CC-EIA system from the point of view of EIA practitioners. In all, 63 respondents were drawn across the country. It was found that majority practitioners believed that CC is highly relevant in EIA and Strategic Environmental Assessment (SEA). In addition, the survey suggested that project EIAs cannot take lead in incorporating CC EIA. CC considerations must start or originate from SEAs.

Major barriers to project EIA being able to address CC were ranked as follows:

1. Lack of government policy and incentives to address CC in EIA
2. Lack of political and agency will to address climate change.
3. EIA scoping does not address CC i.e. which projects need to address CC
4. Lack of expertise and appropriate EIA tools

Let us understand the complexity of the issue.

CC considerations in EIA typically result into mitigation and adaptation plans. The adaptation plans need to be developed at regional level, often beyond the boundaries of an individual project. For designing and implementing adaptation related plans, a simultaneous consideration to multiple projects is required to assess the cumulative impacts over the region. Public consultations need to be used as an important milestone to link the SEA, REA and Project level EIAs.

Another point to remember is we need to bring in elements of risks by building scenarios.

The entry point for developing adaptation plan is thus at strategic level where tools such as Regional EIA (REIA), SEA and Cumulative Impact Assessment (CIA) need to be used.

Unfortunately, in India all these three extensions of Project EIA have not been legislated. If we want to address CC in Indian EIA, then we will require a major reform in the EIA system.

The mitigation plans on the other hand are generally project-limited and influence the project design and operations. Here aspects such as energy mix, water use and conservation, afforestation and erosion control need to be examined. Many of these aspects get addressed in the preparation of Project focused Environmental Management Plan (EMP).

To address abnormal and emergent situations however, the Project level EMPs need to be accompanied by the Disaster Management Plan (DMP). Once CC considerations are included, adaptation and mitigation elements get factored and the DMP assumes a form of a Disaster Risk Reduction Plan (DRRP). This DRRP needs to address both onsite and offsite risks.

Management of onsite risks become a part of the Project EIA while the management of offsite risks need to be integrated with regional DRRP. Both EMP and DRRP need to abide by the framework of the REA and SEA with clear institutional and cost sharing arrangements. Again, DRRP needs to be “synchronized” with the adaptation related plans at the regional level – especially on matters related to policy, plans and supporting commonly shared infrastructure. I have attempted to show the relationships between SEA/REA, Project level EIA, EMP and DRRP in the context of CC   integration. (See Figure 1)

Figure 1: Integration of CC consideration in EIA

Project EIAs are generally processed by State and Central level environmental authorities. Separate departments/ministries operate for management of disaster related risks.  Often, there are no linkages occur between these institutions. SEA with a focus on CC may be used to ensure mainstreaming of CC   in the project and regional EIAs and more critically to ensure coordination between key institutions and the project sponsor.

 Key stakeholders in the CC integration will be National/Regional Planning agencies, Environmental and Disaster Management Agencies and the Project Proponent. Table 1 lists roles and responsibilities of key stakeholder institutions in the conduct of SEA, Regional EIA and Project EIAs.

Table 1 – Roles and Responsibilities of Key Stakeholder Institutions

 Many States in India have set up CC cells. These cells may undertake required coordination. These CC cells may be supported by a CC related research organization that has required databases and expertise on CC related modelling. This concept is shown in Figure 2.

Figure 2: Institutional Arrangements for Mainstreaming CC considerations in EIA

REA and SEA clearly assume an important role to ensure harmonization between Project level EMP and DRRP with the CC adaptation plans at the regional level. Cumulative Impact Assessment (CIA) will remain the key. Institutional coordination with cost sharing will be important in the implementation of the CC related recommendations. Involvement of the stakeholders is necessary to appreciate the concerns of the CC, especially its economic, social and environmental implications. Capacity building of the planners, regulators and professionals is also required. Finally, pilots should be implemented to demonstrate how CC in EIA could be mainstreamed. Based on the experience of the pilot, the EIA Notification may be suitably amended. We will need to develop another Schedule that will define which projects or regions will need CC considerations based on the vulnerability atlas, type and scale of projects development.

I presented my views to my Professor Friend.

He laughed “Don’t get so critical Dr Modak!” He said

“The Ministry likes you. The least MoEFCC will do is to constitute a “Committee on CC in EIA”. They are good at this and I am sure this Committee will be set up without much delay!! But remember, rest will follow as usual. Like the Climate is changing, MoEFCC may also change its mind!!!

This post draws from the paper I presented at the Impact Assessment the Next Generation 33rd Annual Meeting of the International Association for Impact Assessment 13 – 16 May 2013, Calgary Stampede BMO Centre | Calgary, Alberta, Canada. This paper was co-authored with Namrata Ginoya who worked with me at the Environmental Management Centre LLP

If you like this post then please follow me or forward this post to your colleagues