December 1997

EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

12.0 Reviewing and Evaluating an EIA Report

12.1

Introduction

An Environmental Impact Assessment (EIA) report is normally reviewed once it has been completed,
before being submitted to the decision making authority. The main purpose of the review is to verify that the
information and conclusions presented in the EIA report are sufficient for informed decision making. In most
countries the formal review is undertaken by a governmental environmental review agency. The results of the
review are then passed on to another agency for ultimate approval of the development project.
In spite of the important role that EIA information plays in project approval processes, the quality of EIA
reports is highly variable. The scientific and technical information upon which environmental assessment decisions
are being made is often inadequate. In a recent review of EIAs submitted to the Asian Development Bank (ADB,
1993), reports were evaluated for both their compliance with the Banks prescribed format and the substance of
the information provided. This review showed that EIA reports submitted to the ADB still require improvement.
Two primary reasons for poor quality EIA reports are lack of qualified environmental experts, and
insufficient time and money. An additional cause is inadequate terms of reference (TOR) for the EIA study.
Perhaps the main reason why poor quality EIA reports are still being prepared, however, is the lack of concerted
effort by government environmental agencies to force improvements. Review authorities are not very rigorous in
their review of EIA reports. This is evident in that there are few systematic approaches for review and evaluation.
Problems in EIA reports are often identified during the review stage, however information on how to correct these
problems and thus improve future reports is not being passed on to the consultants and academics who prepare
them. Hopefully, the requirements of review authorities will become more stringent and the capabilities of
reviewers will improve. This will lead to gradual improvements in EIA report quality.
This chapter outlines the main considerations in a proper review and evaluation of an EIA report. It
follows Sadler (1996) in using the triple A-test of appropriateness (coverage of key issues and impacts), adequacy
(of impact analysis), and actionability (does the report provide the basis for informed decision making?).

12.2

Review Criteria
An EIA report should satisfy three criteria:
1. completeness and conformance with the TOR for the EIA;
2. accuracy and veracity as defined by general acceptable scientific criteria (for example, quality
assurance and quality control procedures for analysis of sampling data) and use of acceptable
methods for the assessment of environmental impacts; and
3. clear description of environmental impacts, recommended mitigation measures, environmental
monitoring plan, and environmental management plan.

12.3

EIA Report Quality Control

The EIA should be critiqued internally before being released for formal review by the EIA review
authority. This critique should be undertaken to ensure the environmental assessment is complete, and that all
tasks in the TOR have been performed satisfactorily. If the critique indicates that some requirements have not
been met, they should be clearly defined for additional attention. The output of the critique is a written set of
-1

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

instructions on the additional work to be done by the EIA team. The critique is the quality control step for an EIA
report. This is a critical step in the EIA process, as the outcome may affect the environmental acceptability of the
proposed project.
The purpose of the critique is to ensure the final EIA reports sent to governmental agencies and other
funding agencies for review and approval are complete, and present as accurate a picture as possible of the likely
environmental effects of the project. The critique confirms that all significant issues have been addressed and that
provisions for the management of these issues are contained in the EIA report. The critique ascertains that all
tasks listed in the TOR for the EIA have been performed, especially the special requirements of any involved
international assistance agencies.
A team of environmental and technical specialists normally assists with the critique of the EIA. The most
practical approach to critiquing is first to examine the EIA reports Table of Contents to check that all the items
required by the TOR are included. Each report section should then be reviewed to ensure it has been adequately
handled; the TOR should be used for this purpose. In the Peoples Republic of China, quality control of the EIA is
a specific step in the EIA process (Box 12-1).

Box 12-1:

Critiquing EIA in the Peoples Republic of China

Once the EIA practitioners have completed the EIA report, it is reviewed prior to submission to the National Environmental Protection
Agency or the Provincial Environmental Protection Bureau. This review may be undertaken by the staff or consultants of the project
proponent. In some cases, special groups within environmental research institutes have been sent up to ensure quality is maintained in all
EIA reports.

12.4

Formal Review of the EIA Report

Formal review of the EIA report is undertaken by a review authority that is part of the EIA administrative
agency. In many cases, a technical review by agency staff occurs prior to the formal review by the review
authority.
12.4.1 Two Approaches to Review
The review occurs at two distinct levels, both of which are required. There is also much interaction
between levels (Schibuola and Byer, 1991). The first level is a systematic review of each major step or aspect of
the EIA. Methods and approaches used are critiqued both on technical grounds and based on what is expected.
The TOR may be used to define what is expected. Review at this level may be made on: 1) conformance and
completeness as defined by the TOR; 2) accuracy and veracity as defined by general acceptable scientific criteria
(for example, quality assurance and quality control procedures for analysis of sampling data); and 3) use of
acceptable methods for assessment of environmental impacts.
The first level of review requires a standard (that is, the ideal EIA report) for comparison. While the TOR
come closest to defining what should be in the ideal EIA, they are only useful if properly prepared if the terms
of reference are inadequate and imprecise, they will not serve as useful guide for the reviewer. It is, in fact,
difficult to see how an EIA can be systematically evaluated without a well defined TOR for the EIA report. With
knowledge of the TOR, the reviewer can easily search through the EIA to determine its completeness and

-2

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

conformance to the TOR. The Calyx-ADB expert system described in Chapter 8 uses this approach. Based on the
TOR generated by the system, a review checklist is prepared that may be used to evaluate the EIA report.
The second level of review, which probes deeper into the EIA, does not rely on an objective standard for
evaluation. It does rely on common sense, world knowledge, and understanding of the context and setting for the
EIA. For example, a reviewer may notice, that in the analysis of alternatives, the preferred alternative is the one
that was preferred by the proponent prior to conducting the environmental assessment (Schibuola and Byer,
1991). If the level one review indicates the methods used or the veracity of the results is in question, this
knowledge may cause the reviewer to argue that the EIA is biased in favor of the proponents preferred
alternative.
12.4.2 Section-by-Section Review of the EIA Report: A Checklist
This section, organized according to the table of contents for a typical EIA report as presented in
Chapter 11, provides a list of what to look for in each section of the EIA report.
Executive Summary
an adequate summary of the significant findings of the EIA report
a sufficiently detailed description of how significant environmental issues will be resolved enough
to allow the reader to grasp its importance and scope, as well as the appropriateness of the approach
taken to resolve
a presentation of the studys conclusions
effective, simple visual presentations of the type and magnitude of the impacts
Introduction
the project rationale
methods used to identify, predict and assess impacts
a review of similar projects
the purpose and overview of the report
Project Description
a listing of project activities that are likely to cause significant impacts to environmental resources
a listing of mitigation measures to be incorporated into the project
the location, scale, and scheduling of activities
potential accident or hazard scenarios covered in the risk assessment are based on the characteristics
of the project and the history of accidents at similar types of facilities
information should match the expected operations according to the feasibility study

-3

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

Description of the Environment

a description of the environmental components that may be significantly affected by the project
an explanation of the derivation of environmental indicators chosen to represent environmental
components
base maps for spatial data (Base maps are an extremely valuable tool to orient the intended audience
of the EIA report with regard to the distribution of the various resources, and their proximity to the
project site. The map legends must be clear for each resource, and the maps easy to read and
accurately scaled. All of the major topographical and land use features in the project area should be
included on the maps. A common mistake in many developing country EIAs is to use the feasibility
study maps. Feasibility study maps contain much information that is superfluous for EIA purposes.
Experience has shown that the presence of carefully planned environmental base maps is a good
indicator of the quality of an EIA report (Ludwig et. al., 1988).)
baseline values, or some other appropriate form of quantitative and qualitative information, for
resources that may be affected either directly or indirectly by project activities (Baseline values are
important because they represent the pre-existing conditions that the environmental protection
measures identified in the EIA are intended to preserve to the extent possible, within
economic -cum-environmental development constraints.)
Anticipated Impacts
a description of the major issues
documentation of the cause and effect relationships between planned project activities and the
environmental components
identification of secondary or higher order effects, with clearly defined pathways of impacts from
higher order effects
impact prediction includes a number of stated assumptions that affect the predicted impacts, their
probability of occurrence and degree of impact
methods used to predict impacts
an assessment of the significance of predicted impacts
methods or approaches to assigning impact significance
justification for the choice of methods used to predict environmental impacts (This can be based on a
review of the previous use of the model, which can be substantiated by a review of relevant
published scientific and technical articles and reports.)
Mitigation Measures
a description of all the environmental protection measures considered to mitigate or offset damaging
environmental impacts from project activities
a description of the costs and benefits for each recommended environmental protection option
developed to resolve a significant environmental issue, as well as a comparison of each option to the
other options; the justification for a recommended option must include an explanation of how its cost
was weighed against the projected reduction in value of the environmental resource
appropriateness and cost effectiveness of environmental protection measures
.

a description of the technology used in each environmental protection measure, including information
regarding its prior effective use, the range of environmental conditions under which it is effective,
and the level of skill required to operate or maintain the technology

-4

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

a time schedule for implementation of the environmental protection measures, showing that they will
be in use before the project impacts are felt
a drawing or table that illustrates how the mitigation measures address the significant environmental
issues
Alternatives
an acceptable evaluation method
a definition of environmental factors
a comprehensive listing of environmental factors considered
an acceptable range of alternatives
a defined method of scaling
a defined method of weighting
a defined method of aggregation
a correctly applied method
explicitly stated assumptions
uncertainty considered
Environmental Monitoring Plan
monitoring objectives (that is, is monitoring linked to determine actual effects and effectiveness of
environmental protection measures)
well specified questions to be addressed by the monitoring program
clearly defined measurable environmental indicators
a sampling design (frequency, intensity) sufficient to provide the information necessary to answer
questions
analytical system quality assurance and quality controls are effective
information for reporting monitoring results in place
Additional Studies: Environmental Economics
evaluation method acceptable
environmental factors defined
environmental factors comprehensive
methods for valuation of environmental components described
methods applied correctly
assumptions explicitly stated
uncertainty considered
Additional Studies: Public Participation
strategy and approach
chronology of individuals and groups consulted
descriptions of methods used to consult with public

-5

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

summary of information obtained during consultations and how it was used in preparation of the EIA
report
Environmental Management Plan and Environmental Management Office
detailed descriptions of the environmental protection measures, the monitoring program, and a variety
of other required follow-up activities
monitoring requirements
staffing requirements
budgets and schedules
administrative arrangements
administrative mechanisms for enforcement and taking corrective action are in place
Summary and Conclusions
net benefits which justify the project
explanation of how adverse effects have been mitigated
explanation of use or destruction of any irreplaceable components
provisions for follow-up surveillance and monitoring
Annexes
quality of relevant background documents
quality assurance of data presented
assessment of people contacted
reliability of data sources

12.5

Problems in Conducting EIA Reviews and Evaluations

The expertise required for EIA review is essentially the same as that required for preparing the EIA
report. While it is desirable that the first stage of the review be done by technical staff in the EIA administration
agency, in most developing countries, the EIA administrative agency is short on the necessary environmental
expertise required to conduct the review. The usual solution to this problem is to furnish these skills to reviewers
in the EIA administrative agency through either training or use of advisory committees composed of academics or
consultants from the private sector. In Thailand, where advisory committees are used (see section 2.10),
experience has shown that the advisory committee members themselves (despite the high status in the developing
country) may lack sufficient expertise.
There are very real constraints on the availability of environmental information to be used in an EIA
report. Time and budgets often do not allow for extensive new data collection and there is considerable reliance on
existing and secondary data. In spite of this, most EIAs provide considerable background information on the
environment. The problem is that they often provide little else. Where they are most obviously lacking is in the
assessment or prediction of impacts and in the provision of details of appropriate environmental protection
measures.

12.6

References and Further Reading

-6

December 1997
EIA for Developing Countries

Chapter 12: Reviewing and Evaluating an EIA Report

Asian Development Bank, 1993. Environmental Assessment Requirements and Environmental Review
Procedures of the Asian Development Bank. Office of Environment, Asian Development Bank, Manila, Philippines.
44 pp.
Ludwig, H.F., et. al. 1988. Environmental Technology in Developing Countries. South Asian Publishers, New
Delhi, India.
Ross, W.A. 1994. Environmental impact assessment in the Philippines: progress, problems, and directions for the
future. Environmental Impact Assessment Review, 14: 217-232.
Sadler, Barry. 1996. Environmental Assessment in a Changing World: Evaluating Practice to Improve
Performance. Final Report of the International Study of the Effectiveness of Environmental Assessment. Minister
of Supply and Services (Canada), Ottawa, ON.
Schibuola, S. and P.H. Byer. 1991. Use of knowledge based systems for the review and evaluation of
environmental impact statements. Environmental Impact Assessment Review, 11: 11-27.

-7