DOES ENVIRONMENTAL IMPACT ASSESSMENT FACILITATE ENVIRONMENTAL MANAGEMENT ACTIVITIES?

8/17/2019 DOES ENVIRONMENTAL IMPACT ASSESSMENT FACILITATE ENVIRONMENTAL MANAGEMENT ACTIVITIES?

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Journal of Environmental Assessment Policy and Management

Vol. 2, No. 1 (March 2000) pp. 1–17

© Imperial College Press

DOES ENVIRONMENTAL IMPACT ASSESSMENT FACILITATE

ENVIRONMENTAL MANAGEMENT ACTIVITIES?

TRACEY NITZ

School of Environmental Planning

Griffith University, Nathan QLD Australia 4111

E-mail: [email protected]

IAN HOLLAND

Key Centre for Ethics Law Justice and Governance

Griffith University, Nathan QLD Australia 4111

E-mail: [email protected]

The aim of environmental impact assessment (EIA) is to ensure effective environmental

management outcomes for development projects. Some argue it has failed to achieve this,because environmental management activities are not properly planned in the EIA process.

The extent of this problem is largely unknown, due to a lack of empirical evidence.

This paper presents the results of research investigating environmental management

planning within EIA in the state of Queensland, Australia. The study examined environmental

management commitments within 285 environmental impact statements (EISs).

The majority of the EISs contained environmental monitoring and mitigation

commitments and more than half identified corrective actions. This suggests that EIA

facilitated environmental management within some developments. Nevertheless, many

environmental management activities were not addressed in EISs, even when specifically

requested.Trends in environmental management planning over time revealed dramatic

improvements. These appeared to have resulted from an increase in government requirements

for, and the provision of guidelines to assist, environmental management planning. These

findings suggest improved environmental management must be facilitated by government

agencies, rather than relying upon industry innovation.

Keywords: environmental management, environmental impact assessment, environmental

management plan, empirical analysis

Using Environmental Impact Assessment to Plan forEnvironmental Management

Environmental impact assessment (EIA) is one of the major tools relied upon

by governments and societies worldwide to achieve environmental management.

J . E n v . A s s m t . P o l . M g m t . 2 0 0 0 . 0 2 : 1 - 1 7 . D

o w n l o a d e d f r o m w w w . w o r l d s c i e n t i f i c . c o m

b y T E C H

N I O N - I S R A E L I N S T O F T E C H N

O L O G Y o n 0 3 / 1 3 / 1 3 . F o r p e r s o n a l

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2 T. Nitz & I. Holland

It is primarily used to assist them in the identification, prediction and mitigation

of the environmental impacts of their activities (Dipper et al., 1998; Sadler,

1996; EPA, 1996).There is general agreement that EIA has led to improvements in the environmental

management of development activities (EPA, 1996; McDonald & Brown, 1995;

Bailey, 1997). However, the development of EIA theory and practice has been

accompanied by the accumulation of a significant body of literature identifying

numerous weaknesses in EIA processes and practice. These include criticisms

of the timing of the EIA process relative to project planning and design and

the poor scientific quality of many EIA studies (James, 1995; McDonald &

Brown, 1995; Buckley, 1989; Fairweather, 1989). EIA processes are also criticised

for allowing inadequate public involvement, inconsistently requiring EIA

procedures, facilitating a view of EIA as a reactive planning tool and numerous

other weaknesses (Leu et al., 1996; James, 1995; Brown & Hill, 1995; Buckley,

1989).

The absence of “follow-up” environmental management activities within most

jurisdictions is often identified as the most critical weakness of EIA practice

(Dipper et al., 1998; Sadler, 1996; Buckley, 1989; Ortolano & Shepherd, 1995;

Bisset & Tomlinson, 1988; Buckley, 1989; EPA, 1996). Follow-up environmental

management activities include tasks such as mitigation, monitoring, reportingand auditing of the environmental impacts of development. These activities,

undertaken by both project proponents and government agencies, are conducted

after a development proposal is approved.

The recognition of problems within EIA practice have led to numerous studies

providing suggestions for improvement, including an international study of the

effectiveness of environmental assessment (Sadler, 1996). That study identified

strengthening follow-up environmental management activities as one of the major

priorities for improving EIA effectiveness. Ultimately, improving environmentalmanagement within EIA will help ensure more environmentally acceptable

development outcomes (Sadler, 1996; Hickie & Wade, 1997).

This paper, therefore, focuses on the environmental management activities

within EIA. As perhaps the most widely adopted and accepted environmental

management tool, it is particularly instructive to examine the environmental

management outcomes of EIA. Within EIA, there is also a range of factors

which may influence environmental management activities. In particular,

environmental management activities can be influenced by

• Design changes in the pre-decision stage of EIA

• Environmental management commitments within EISs

• Environmental management conditions on project approval



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Does Environmental Impact Assessment Facilitate Environmental Management Activities? 3

• Environmental management activities implemented in the operational

development

•

Enforcement of approval conditions by government agencies in the operationaldevelopment

Arguably, the first step in improving environmental management activities

is to get project proponents to identify project environmental management strategies

during the planning and approvals process, i.e. the pre-decision stage (Bailey,

1997; Brown & Hill, 1995). This paper explores this aspect of follow-up

environmental management.

The Research Project

During the 1990s there were two main Queensland Acts requiring EIA, the

State Development and Public Works Organisation Act 1971 and the Local

Government (Planning and Environment ) Act 1991–1998 [LG(P&E) Act]. As

the majority of EIAs were conducted under the LG (P&E ) Act , this paper reports

analysis of only those prepared under that Act. Under the LG (P&E ) Act government

prepares the terms of reference (TOR) for an EIA, and proponents prepare an

environmental impact statement (EIS) under the guidance of this TOR.This study examined whether TOR for EIA in Queensland have requested

follow-up environmental management activities as an integral element of EIS

preparation, and whether proponents have responded to those requests. Through

this analysis we aim to add to the currently limited research on the extent of

follow-up activities within EIA systems.

The research project examined environmental management commitments made

within 285 EISs. This paper reports the nature of government requests for follow-

up commitments in the TOR for the EISs. These requests are then compared

with those follow-up commitments within the EISs. Trends in environmental

management commitments over time are identified and explained. The paper

concludes with a discussion of the implications of these results for the use of

EIA in enhancing follow-up environmental management activities.

The Study Methodology

This study was based on empirical analysis of the EIA process leading up to

the point of project approval. The study examined all EISs prepared in Queenslandunder the LG (P&E ) Act for the period 1990 to 1998 for which complete documents

were available from Queensland Government Departments. A total of 285 TORs

and EISs were obtained for review. Each TOR and EIS was read and the nature





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of environmental management commitments recorded using a standard data sheet.

The data sheet was used to record the presence of requests for environmental

management commitments in TORs, and the presence and degree of detail of those provided in EISs (see also Amir & Mosseri, 1997). A total of 20 parameters

were recorded for each project TOR and 14 parameters for each EIS.

There is a wide range of follow-up environmental management activities that

can be undertaken. A review of the environmental assessment literature was

used to define the range of activities investigated in this study (see, for example,

Horberry, 1996; Au & Sanvicens, 1996; BCC, 1996; Brew & Lee, 1996). The

resultant list of activities ranged from the development of performance indicators

to the use of external reporting, and are identified and defined below:

Activities, undertaken by proponents and

regulators, such as mitigation, monitoring,

reporting and auditing of the environmental

impacts of development

Management measures to reduce environmental

impacts to acceptable levels (BCC, 1996)

Aims of the monitoring and management

procedures (Bisset & Tomlinson, 1988)Strategies to monitor important features of the

environment to identify environmental impacts

of the development (Wood, 1994)

Criteria which specify the acceptable level of

impact, against which the results of monitoring

can be compared (e.g., legislated standards or

government policy) (EPA, 1996)

Strategies for monitoring environmental

conditions to identify any impacts not predicted

in the EIS (Sanvicens & Baldwin, 1996)

Strategies for monitoring environmental

conditions to identify any differences between

the actual impacts of development and those

predicted in the EIS (Sanvicens & Baldwin,

1996)

Measures to respond to monitoring results which

show unacceptable impact levels (EPA, 1996;BCC, 1996)

Strategies to report on the effectiveness of

mitigation measures and results of monitoring

• Follow-up environmental

management activities

• Mitigation

• Objectives

• Monitoring

• Performance indicators

• Strategies to identify

unpredicted impacts

• Strategies to identify

differences between

actual and predicted

impacts

• Corrective actions

• Internal reporting





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Having gathered this data, we then examined patterns in the requests for,

and adoption of, follow-up environmental management commitments in the TORs

and EISs overall, as well as over time. Non-parametric statistical tests were

used to identify significant trends and differences.1

Study Results

This section of the paper identifies the follow-up environmental management

commitments that were included in the EISs assessed in this study. The content

of EISs in Queensland is also closely related to their terms of reference (TOR),

hence the frequencies of requests for each of the environmental management

activities in the TOR are also presented (Moon, 1998).

Did the Terms of Reference request EIA follow-up activities?

The TOR for the EISs examined in this study were assessed, to identify how

frequently each follow-up activity was requested. Figure 1 shows the frequency

of requests for each follow-up activity in the TOR.

•

External reporting

• Identify responsible

persons

• Management review

within the proponent’s organisation (Au &

Sanvicens, 1996)

Strategies to report on the effectiveness of mitigation measures and results of monitoring

outside the proponent’s organisation (Wood,

1994; Bisset & Tomlinson, 1988)

Allocate responsibility for implementation of

environmental management activities (Au &

Sanvicens, 1996; BCC, 1996)

Strategies for reviewing environmental man-

agement activities in the light of monitoring

and other results (Au & Sanvicens, 1996)

1Contingency table analysis was performed to identify relationships between the variables of interest,

using the SAS statistical package. For the categorical and nominal variables, the log-likelihood ratio

(G2) was used to test whether an association exists between the contingency table variables. This ratio

was used in preference to the traditionally favoured chi-square test of goodness of fit, because it is

more accurate where there are small expected cell frequencies, as is the case in this study (Zar, 1996).The analysis of ordinal variables used the gamma value, which provides a measure of the strength of

association between contingency table variables. This statistic was used because it is more powerful

for detecting positive or negative trends in variables than the chi-square statistic, which ignores the

ordering of variables (Agresti and Finlay, 1997).





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Figure 1 indicates that the following environmental management activities

were requested in more than half of the TORs:

(i) Mitigation strategies;

(ii) Monitoring strategies;

(iii) Corrective actions;

(iv) Internal reporting strategies;

(v) Identification of responsible persons;

(vi) Identification of unpredicted impacts; and

(vii) Identification of differences between actual and predicted impacts.

Figure 1 reveals that mitigation and monitoring strategies were requestedin 90 per cent of the TOR. This suggests that the Queensland government agencies

considered these follow-up activities important. Nevertheless, given that the primary

aim of undertaking an EIA is to ensure effective environmental management,

it is a concern that mitigation strategies were not requested in all of the TOR.

Even fewer TOR (84 per cent) required the proponent to identify corrective

actions for any unacceptable impacts identified. Furthermore, only 32 per cent

of the TOR requested the proponent to identify the standards according to which

the acceptability of impacts would be determined. Given that past studies (Horberry,

1996; Au & Sanvicens, 1996; Bisset & Tomlinson, 1988) have identified the

need for performance indicators and corrective actions to ensure effective

environmental management, the absence of requests for these follow-up activities

is likely to weaken the effectiveness of project environmental management.

Fig. 1. TOR requests for follow-up commitments.

n = 285

0

10

20

30

40

50

60

70

80

90

100

M i t i g a t i o n

M

o n i t o r i n g

P e r f o r m a n c e i n d i c a t o r s

C o r r e c t i v e a c t i o n s

O

b j e c t i v e s

I d e n t i f y r e s p o n s i b i l i t i e s

I n t e r n a l r e p o r t i n g

E x t e r n a l R e p o r t i n g R e v i e w

I d e n t i f y u n p r e d i c t e d

I d e n t i f y d i f f e r e n c e s

% T

O R r e q u e s t e d





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It is also interesting to note that while strategies for reporting monitoring

results within the development management structure (variable name — internal

reporting) were requested in 88 per cent of the TOR, reporting these resultsto external bodies such as regulatory agencies was requested in only 12 per

cent of these TOR. This suggests that the focus of government agencies preparing

the TOR was on ensuring environmental management occurred within the

development, rather than on ensuring compliance and providing feedback on

the accuracy of EIA predictions by reporting to external agencies.

Figure 1 also indicates that follow-up review strategies were requested in

16 per cent of the TOR. The absence of requests for follow-up review strategies

from the majority of the TORs is also of concern, as the continual review of

environmental management activities in light of monitoring results is essential

to ensuring their continued effectiveness (Horberry, 1996; Sadler, 1996; Morrison-

Saunders, 1996).

Did proponents include EIA follow-up commitments in the EISs?

The frequency of TOR requests for EIA follow-up commitments can be compared

with the actual commitments within the EISs. The EISs were assessed according

to a scoring system, adapted from a system used by Amir and Mosseri (1997),which reflected the level of detail in which the commitments were provided

and whether they had been requested in the TOR. The frequency and level

of detail of commitments for each environmental management activity in the

EISs examined in this study is shown in Fig. 2.

Fig. 2. Nature of follow-up commitments in EISs.

n = 285

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

M i t i g a t i o n s t r a t e g i e s

M o n i t o r i n g s t r a t e g i e s

P e r f o r m a n c

e I n d i c a t o r s

C o r r e c t i v e a c t i o n s

O b j e c t i v e s

I d e n t i f y r e s p o n s i b i l i t i e s

I n t e r n a l r e p o r t i n g

E x t e r n a l r e p o r t i n g

R e v i e w

I d e n t i f y u n p r e d i c t e d

I d e n t i f y d i f f e r e n c e s

% o

f E I S s

Provided Partly provided Not provided





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Figure 2 indicates that there is considerable room for improvements in

commitments to undertake environmental management activities within the

Queensland EIA process. Of the 11 follow-up activities examined, only mitigationstrategies were fully provided in more than 50 per cent of the 285 EISs. As

discussed earlier, ensuring effective environmental management is the primary

goal of EIA. Thus this absence of commitments to undertake even the most

basic and fundamental follow-up activities indicates a major weakness in the

Queensland EIA process.

Of the remainder of the follow-up activities, the following were fully provided

in more than one-third of the EISs:

(i) Monitoring strategies;(ii) Objectives;

(iii) Identification of responsible persons; and

(iv) Internal reporting strategies.

Thus, seven important EIA follow-up activities examined in this study were

provided in less than one-third of the EISs.

The results also suggest other deficiencies. Figure 2 indicates that monitoring

strategies were provided in half of the EISs. The performance standards with

which monitored impacts must comply, and the actions to be taken to correct

any unacceptable impacts were provided in less than 30 per cent of the EISs.

This suggests that the effectiveness of any monitoring strategies is compromised

by the potential inability of proponents to actually identify and correct unacceptable

impacts.

This analysis also shows that the potential for improving the predictive capacity

of EIA through follow-up activities is not being utilised. Commitments to identify

differences between EIS predictions and the actual impacts of projects and to

identify any unpredicted impacts were provided in less than 10 per cent of theEISs (Fig. 2). This leaves little opportunity for providing feedback about the

accuracy of the predictive tools used in these EIA studies by undertaking post-

auditing studies, as advocated by Dipper, Jones & Wood (1998).

Figure 2 also indicates that follow-up review strategies were provided in

only 10 per cent of the EISs. This suggests that there was little focus on ensuring

the continued effective management of the environmental impacts of developments.

This confirms that proponents fail to appreciate the benefits of conducting continuous

EIA follow-up activities (Dipperet al

., 1998).One interesting, and perhaps unexpected, result depicted in Fig. 2, is that

the disparity between requests for internal and external reporting strategies in

the TOR is not mirrored in the EISs. The relatively high level of external reporting

strategies in EISs may be a result of some proponents recording in EISs their





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external reporting commitments required under other legislation, for example,

as a condition of an environmental license issued under the Environmental Protection

Act (Queensland) 1994. Alternatively, the willingness of some proponents toinclude internal and external reporting commitments in their EIS, regardless of

whether they were requested in the TOR, may be a reflection of their view

of EIA as a “paper chase to secure a development permit”, rather than a real

commitment to undertake these follow-up activities (Au & Sanvicens, 1996).

On the whole, these results suggest that comprehensive environmental

management commitments were rarely evident within the Queensland EIA process.

However, these results provide an indication of follow-up commitments within

EISs only. As such, the absence of many follow-up commitments from a considerable

proportion of EISs does not necessarily mean effective environmental management

activities were not occurring within operational developments. It does, however,

indicate that the Queensland EIA process was rarely used by proponents to

plan for effective environmental management within their proposed development

nor to improve future EIA practice. This represents a missed opportunity within

the EIA process (Dipper et al., 1998).

Were there any trends in EIA follow-up commitments?

Despite this dismal picture of environmental management activities within the

Queensland EIA process, this study also revealed significant increases in follow-

up commitments over time. Statistical analysis was performed to identify any

trends in the follow-up commitments in the EISs submitted in different years.

This analysis revealed that there were statistically significant increases in the

number and level of detail of follow-up commitments in EISs submitted in later

years. This was the case for all 11 of the follow-up activities examined in

this study.Figures 3–5 show the trends in the provision of performance indicators, external

reporting and follow-up review strategies in the EISs, respectively. As the trends

were similar across the different follow-up activities, to avoid repetition, the

results are depicted for these three activities only. Of the 11 follow-up activities

examined in this study, the most significant increases over time occurred in

the provision of monitoring strategies, corrective actions, performance indicators,

internal reporting strategies and the identification of responsible persons.

Figures 3–5 show that, consistent with the level of provision of follow-up

commitments in all of the EISs, the trends over time differ between the follow-

up activities. While the level of commitments for some follow-up activities increase

gradually over time, such as follow-up review strategies (Fig. 5), others, such

as performance indicators (Fig. 3), increased dramatically at one point in time.





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0%

20%

40%

60%

80%

100%

1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17

% o

f E I S s


0%

20%

40%

60%

80%

100%

1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17

% o

f E I S s


0%

20%

40%

60%

80%

100%

1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17

% o

f E I S s

Provided Partl provided Not provided

Fig. 3. Provision of performance indicators in EISs over time.

Fig. 4. Provision of external reporting strategies in EISs over time.

Fig. 5. Provision of follow-up review strategies in EISs over time.





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This may suggest that the increases in commitments were a result of different

factors. For example, the dramatic increase in provision of performance indicators

from 1994 to 1995 may have been a result of similar requirements for thisinformation in order to obtain an environmental license under the Environmental

Protection Act (Queensland) 1994.

The results also reflect the willingness of proponents to commit to some

follow-up activities more readily than others. Figures 3 and 4 indicate that the

provision of performance indicators in EISs increased to over 75 per cent of

those submitted in 1998, whereas the provision of external reporting strategies

increased to only 50 per cent of the EISs submitted in 1998. Furthermore, Fig. 4

shows that the provision of follow-up review strategies increased to just under

30 per cent of the EISs submitted in 1997. Thus, while the increase in follow-

up commitments was significant for all of the activities, some activities enjoyed

more significant increases than others.

What are the causes of these trends?

To capitalise on the encouraging trend of increasing environmental management

commitments in EISs in Queensland, and to provide lessons for other jurisdictions,

it is important to identify the factors causing these trends. A number of factorswhich influence the effectiveness of EIA have been identified, such as procedural

control, professional control and the provision of government guidance (Ortolano

et al., 1987; Dipper et al., 1998; Moon, 1998).

Ortolano et al. (1987) and Dipper et al. (1998) both suggest that the

role of governments in EIA processes, i.e. procedural control, influences the

effectiveness of EIA. Dipper et al. (1998) argue that to encourage EIA follow-

up “the possibility of developing mandatory requirements and/or central guidance

for EIA follow-up needs further exploration”. Statistical analysis was performedto investigate the influence of these factors.

Figures 6–8 depict the trends in TOR requests for performance indicators,

external reporting and follow-up review strategies, respectively. As for the trends

in follow-up commitments in EISs, the trends in TOR requests were relatively

consistent amongst the different follow-up activities, consequently, the results

are provided for these three activities only.

These figures indicate that there were considerable increases in TOR requests

for these follow-up commitments between 1990 and 1998. For instance, Fig. 6

reveals an increase in TOR requests for performance indicators from no requests

in 1991 to requests in over 90 per cent of TOR in 1998. Analysis revealed

that there were statistically significant increases over time in requests for all

of the environmental management activities examined, with the exception of





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0

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1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17

% o

f T O R r e q u e s t i n g p e r f o r m a n

c e

i n d i c a t o r s

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1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17 % o

f T O R r e q u e s t i n g e x t e r n a l r e p o r t i n g

s t r a t e g i e s

Fig. 6. Requests for identification of performance indicators in TOR over time.

Fig. 7. Requests for external reporting strategies in TOR over time.

0

10

20

30

40

50

60

70

80

90100

1991 n=16 1992 n=43 1993 n=50 1994 n=35 1995 n=48 1996 n=41 1997 n=35 1998 n=17

Fig. 8. Requests for follow-up review strategies in TOR over time.





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mitigation strategies and corrective actions. This suggests that over time, and

with increasing experience with environmental management activities, Queensland

government agencies began to recognise the importance and potential benefitsof EIA follow-up activities.

As with trends in follow-up commitments in EISs, Figs. 6–8 also indicate

that the trends differed for different follow-up activities, with over 90 per cent

of TOR in 1998 requesting performance indicators, whereas just over 50 per

cent of these TOR requested follow-up review strategies. This may suggest that

government agencies have had more experience with some follow-up activities

than others, or alternatively, consider some activities more important than others.

Most importantly, however, these results indicate that improvements in

environmental management commitments in Queensland appear to have resulted

from increasing government agency requirements. This provides empirical evidence

to support claims that one important strategy for improving follow-up environmental

management is the introduction of mandatory requirements for follow-up

commitments and activities as a part of the EIA process (Dipper et al., 1998).

Another strategy for improving EIA follow-up identified in this study is the

provision of detailed government guidance to assist proponents in planning and

implementing environmental management activities. Such guidance was developed

by the Queensland Department of Environment and accompanied the TOR requestsfor follow-up commitments from April 1996 onwards. This document, Guidelines

for the Preparation of Environmental Management Plans, provided detailed advice

regarding the purpose, components, format and an example of comprehensive

environmental management commitments (Queensland Department of Environment,

1996).

Statistical analysis revealed that the inclusion of the guidelines with the TOR

resulted in a significantly greater level of provision of follow-up commitments

in EISs. This was the case for all of the follow-up activities, except mitigationstrategies, which were usually included in EISs irrespective of the inclusion

of the guidelines. Figures 9–11 show the differences in provision of performance

indicators, external reporting and follow-up review strategies in EISs where the

guidelines were and were not provided, respectively. These results suggest that

the trend of increasing follow-up commitments over time, in particular,

improvements from 1996 onwards, may also be a result of the provision of

the follow-up planning guidelines.

Another potential strategy for improving follow-up environmental management

commitments is through increased awareness of their potential benefits amongst

EIA consultants and other environmental practitioners (Ortolano et al., 1987).

The potential for “professional control” to have influenced trends in environmental

management commitments in this study appeared limited, as 71 per cent of





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0

20

40

60

80

100

No Guidelines provided n=233 Guidelines provided n=51

% o

f E I S s

Fig. 9. Proportion of EISs containing performance indicators.

0

20

40

60

80

100


% o

f E I S s

Fig. 10. Proportion of EISs containing external reporting strategies.

Fig. 11. Proportion of EISs containing follow-up review commitments.

0

20

40

60

80100


% o

f E I S s





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the EISs were prepared by consultants who prepared only that one EIS during

the study period. It seems unlikely that there is significant professional control

in EIA generally when the consultants preparing EISs have so little to do withthe impact assessment process.

Amongst the few consultants with extensive EIA experience (prepared > 5

EISs in the study period), the picture is a little different. Only one consultant

provided environmental management commitments in more detail than the average,

and that greater level of detail was confined to performance indicators, external

reporting and environmental management review strategies. This suggests that

EIA practitioners may have limited potential to influence follow-up environmental

management activities. However, what is worth noting is that this one consultant

was preparing EISs for just one type of development: feedlots. Any improvement

in providing environmental management commitments seems, therefore, more

likely to be a result of the consultant having an in-depth knowledge of a particular

development type, rather than being a product of professional control.

Conclusions

The results presented in this paper have provided empirical evidence of EIA

follow-up within Queensland, both within the TOR for EISs, and within theactual EISs. While there is considerable room for improvement, this does suggest

that Sadler’s (1996) argument that EIA follow-up is poorly developed may be

slightly pessimistic. Indeed the trend of increasing follow-up commitments over

time identified in this study suggests that there has been considerable development

in follow-up environmental management activities within the Queensland EIA

process.

However, the examination of causes of increasing environmental management

commitments highlighted the need for government action to encourage thesetrends. Making follow-up commitments a mandatory part of EIA practice is

critical to enhancing planning and implementation of environmental management

activities. This provides empirical evidence to support Dipper et al.’s (1998)

suggestion that developing binding requirements is an important strategy for

improving EIA follow-up.

This study has also provided evidence that government action can facilitate

improvements in environmental management activities through the provision of

detailed guidance to assist proponents. This supports the suggestion that

improvements in other aspects of EIA practice (such as Strategic Environmental

Assessment in England and Wales) are resulting from the publication of detailed

government guidance (Therivel, 1998).





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While this paper has demonstrated the benefits of government action in enhancing

EIA follow-up commitments, it has not ruled out the potential contribution of

other factors, including those identified by Ortolano et al. (1987) as importantinfluences on EIA effectiveness, such as the experience of proponents and EIA

practitioners with follow-up planning, and non-governmental organisation pressure.

Our preliminary analysis, however, suggests there was little potential for EIA

practitioners to influence follow-up environmental management in the Queensland

EIA process.

Acknowledgements

The authors would like to acknowledge the assistance of Ms Edilyn Bajracharya

from the Queensland Department of Environment and Ms Emily Thomas from

the Queensland Department of Housing, Local Government and Planning for

their assistance in locating the EISs. We would also like to thank Professor

Lex Brown for his comments on the paper.

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DOES ENVIRONMENTAL IMPACT ASSESSMENT FACILITATE ENVIRONMENTAL MANAGEMENT ACTIVITIES?

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