ISSUED BY
Department of Environmental Affairs and Tourism
Private Bag X447
Pretoria
0001 South Africa
PLEASE NOTE: This document is intended as an information source and cannot
take the place of legal advice in a specific situation governed by legislation.
The document is not a guideline document, but serves as a reference and supportive
text. This document will not take the place of official guidelines and regulations
published by DEAT.
ENQUIRIES AND COMMENTS
All enquiries and comments should be addressed to:
The Director: Environmental Impact Management
Department of Environmental Affairs and Tourism
Private Bag X447
Pretoria
0001 South Africa
REFERENCING
When referencing this document, it should be cited as follows:
DEAT (2002) Screening, Information Series 1, Department of Environmental Affairs
and Tourism (DEAT), Pretoria.
Preface
This document is one of a series of overview information reports on the concepts
of, and approaches to integrated environmental management (IEM). IEM is a
key instrument of South Africa's National Environmental Management Act (NEMA).
South Africa's NEMA promotes the integrated environmental management of activities
that may have a significant effect (positive or negative) on the environment.
IEM provides the overarching framework for the integration of environmental
assessment and management principles into environmental decision-making.
It includes the use of several environmental assessment and management tools
that are appropriate for the various levels of decision-making.
The aim of this document series is to provide general information on techniques,
tools and processes for environmental assessment and management. The material
in this document draws upon experience and knowledge from South African practitioners
and authorities, and published literature on international best practice. This
document is aimed at a broad readership, which includes government authorities
(who are responsible for reviewing and commenting on environmental reports
and interacting in environmental processes), environmental professionals (who
undertake or are involved in
environmental assessments as part of their professional practice), academics
(who are interested and active in the environmental assessment field from a
research, teaching and training perspective), non-governmental organizations
(NGOs) and interested persons. It is hoped that this document will also be
of interest to practitioners, government authorities and academics from around
the world.
This document has been designed for use in South Africa and it cannot reflect
all the specific requirements, practices and procedures of environmental assessment
in other countries.
This series of documents is not meant to encompass every possible concept,
consideration, issue or process in the range of environmental assessment and
management tools. Proper use of this series of documents is as a generic reference,
with the understanding that it will be revised and supplemented by detailed
guideline documents.
Acknowlwdgements
This document has been prepared by the CSIR. The production of this document
would not have been possible without the valuable comments from the various
authorities, environmental consultants and practitioners who freely gave
of their time to share their experiences.
Special thanks are due to the following people
Dennis Laidler, Western Cape Provincial Department of Environment, Cultural
Affairs and Sport, Cape Town.
Keith Wiseman, City of Cape Town.
Natalie Newman, South Peninsula Administration, City of Cape Town.
Stephen Davey, Cape Metropolitan Council Administration, City of Cape
Town.
Mari Els, WSP Walmsley.
Opinions expressed and conclusions arrived at are those of the authors and
are not necessarily the official view of the Department of Environmental Affairs
and Tourism. Any misrepresentation of views or errors of fact are those of
the authors and are not a reflection of the individuals acknowledged.
All sources used have been acknowledged by means of complete references.
Principal Authors: Frauke Munster and
Mike Burns
Project Managers: Mark Gordon (DEAT) and Nigel Rossouw
(CSIR)
Editorial Review: DEAT: Wynand Fourie, Johan Benade and
Danie Smit
CSIR: Patrick Moran and Michelle Audouin
This document provides an overview of the screening process in integrated
environmental management (IEM). It aims to overcome some of the existing confusion
between the screening and scoping stage of environmental assessment by clarifying
the purpose and definition of screening.
Screening determines whether or not a development proposal requires environmental
assessment, and if so, what level of assessment is appropriate. Screening is
therefore a decision-making process that is initiated during the early stages
of the development of a proposal.
The document differentiates between two types of screening. Mandatory
screening is defined as that process which is typically administered
by an environmental authority or some other institution with vested powers
to instruct and become party to a screening process. Various approaches to
mandatory screening exist, including initial consultations with authorities,
use of lists of actions, activities, projects and/or sensitive environments,
preliminary environmental evaluation, decision-support systems, or the decis
ion-maker’s discretion.
Pre-application screening, on the other hand, is undertaken outside
a formal process, typically at the discretion of a development proponent. Pre-application
screening is the process whereby key environmental issues associated with a
proposed development are anticipated at the earliest opportunity, and are considered
as an integral part of pre-feasibility investigation. Questions pertaining
to the need for, and desirability of the proposed development must be considered,
and issues such as
technology and location alternatives have to be appraised at an appropriate
level of detail. Pre-application screening often involves some form of fatal
flaw analysis.
The responsibilities of different parties involved in the screening proces
s are summarized. However, responsibilities may vary depending on the circumstances
and nature of the screening process. Project and environmental information
required by the screening process is identified.
An overview of screening practices in developing countries and countries in
transition highlights the range of approaches that may be applied, and provides
examples of situations where pre-application screening is currently
applied.
The document concludes with an identification of some of the current challenges
and short-comings associated with screening. These include capacity constraints
by decision-making authorities to undertake effective and adequate screening,
weaknesses associated with relying on lists for screening, difficulties in
assigning impact significance and determining thresholds, and the confusion
arising between the reporting requirements of screening, scoping and a full
environmental impact report.
In the context of integrated environmental management (IEM), screening determines
whether or not a development proposal requires environmental assessment, and
if so, what level of assessment is appropriate. Screening is thus a decision-making
process that is initiated during the early stages of the development of a proposal.
In practice, the purpose of screening is often misinterpreted as an opportunity
to provide decision-makers with the information usually contained in an environmental
assessment in an attempt to gain authorization for a proposal without the need
to proceed further with the environmental assessment process. Apart from burdening
decision-makers with superfluous detail that is unnecessary for making the
screening decision, the information presented will generally have been compiled
without adequate consultation with stakeholders. Key issues that may influence
the decision may therefore have been overlooked.
There is thus a need to refocus on the definition, approaches to, and information
requirements of screening in order to improve the effectiveness and efficiency
of the entire environmental assessment process.
The purpose of this document is to provide an overview of screening, set in
the context of integrated environmental management.
The overview is structured to differentiate between what might be termed mandatory
screening, which is typically administered by an environmental permitting authority
or some other institution with vested powers to undertake the screening process,
and pre-application screening, which is undertaken outside a formal process,
typically at the discretion of a development proponent. In fulfilling this
purpose, the discussion that follows begins with a review of some common definitions
of screening in order to provide a context in which to expand on both the rationale
for, and details of its practical application. Here reference will be made
to screening methods, roles and responsibilities for screening, the objectives
and outcomes of the process, and an overview of screening as it is practiced
in some developing countries and countries in transition. The document concludes
with a summary of some of the challenges and shortcomings of screening practice.
It is not the purpose of this document to provide a set of guidelines on the
practical requirements of undertaking screening. It rather aims to provide
an overview of what screening entails and when it should be undertaken.
A definition of screening provided by Sadler (1996) is that it is a process
involving the determination of whether or not an individual proposal (project,
programme, policy, etc.) requires further environmental assessment, and if
so, what level of detail this assessment should entail.
Other definitions of screening show a high degree of commonality (Box 1).
Box 1: Definitions of screening.
Department of Environment Affairs (DEA, 1992):
"The classification of proposals".
IFC (1998): "...environmental screening of each proposed operation to
determine the appropriate extent and type of environmental assessment".
UNEP (1996): "the process of determining whether or not an individual
proposal requires detailed environmental assessment and the level of
assessment that should occur"
IAIA (1999): "to determine whether or not a proposal should be subject
to environmental impact assessment (EIA), and if so, at what level of
detail."
Wood (2000): "deciding whether the nature of the action and its likely
impacts are such that it should be submitted to environmental assessment."
Considering the definitions of screening that are provided here, it is clear
that screening is a process instituted at an early stage of a proposal’s
life cycle, and that it comprises two important steps. The first step is to
determine whether or not a development proposal requires environmental assessment.
When the outcome of this first step is a decision that an environmental assessment
is to be undertaken, the second step of screening determines the level of the
environmental assessment to be initiated.
The screening process can therefore be compared to the function of a sand
screen that separates fine grains of sand from the gravel or stones. All development
proposals are initially subjected to this "screen". Proposals that have insignificant
environmental impacts and don’t require environmental assessment are
like the fine grains of sand that are small enough to fall through the mesh
of the screen. On the other hand, proposals for which there is inadequate information
to make a decision or where it is clear that the proposal will have significant
environmental impacts, are like the coarser gravels or stones that are caught
by the screen. These proposals will either be rejected outright or will require
environmental assessment. In the case of the latter the appropriate level of
assessment then needs to be determined (see Figure 1).
Figure 1: Alternative outcomes of the Screening Process
In determining whether a proposal requires further environmental assessment,
should be rejected outright, or should be exempt from environmental assessment,
the screening process should take into consideration the alignment of the proposal
with existing policies and plans, the scale of the proposed development, the
intensity of potential impacts and the significance of potential impacts. The
interpretation of whether or not the possible effects of a proposal might be
significant is thus a fundamental aspect of screening.
However, providing an objective definition of significance is difficult. Significance
is largely determined by prevailing societal values that are, in turn, influenced
by the associated social, economic, political and biophysical context. Although
a number of criteria for judging impact significance have been developed, this
remains an element of screening that can expose inconsistencies in the process
and potentially jeopardize its essential purpose. For example, when significance
is not properly determined, a proposed development that may warrant a comprehensive
environmental assessment might be exempted; and conversely, a development that
should be exempted in this regard might unnecessarily be subjected to a comprehensive
environmental assessment. For a more detailed discussion of impact significance
refer to document
5 in this information series.
Integrated environmental management is "a philosophy which prescribes a code
of practice for ensuring that environmental considerations are fully integrated
into all stages of the development process in order to achieve a desirable
balance between conservation and development" (Department of Environment Affairs,
1992). The IEM philosophy, with its supporting principles, is a cradle-tograve
approach that is relevant to the planning, assessment, implementation and management
of any local, national or international proposal (project, plan, programme
or policy) that has a potentially significant effect on the environment and
sustainable development.
Set in the context of IEM, screening holds an important position as a locus
where environmental considerations associated with a proposal can be taken
into account during the planning stages (pre-feasibility or feasibility stages)
and/or the initial stage of the environmental assessment (EA). These considerations
are assessed within the framework of the screening process (Figure 2).
Figure 2: Overview of the Generic Screening Process
In this context of IEM, environmental considerations are first taken into
account either through mandatory screening, which is typically administered
by an environmental authority or funding body, and/or preapplication screening,
which is typically undertaken at the initiative of a development proponent
prior to submitting an application to the lead authority to authorize an activity.
1. Pre-application screening
In terms of the principles of IEM requiring environmental considerations to
be integrated into the development process, it is the responsibility of the
proponent to respond, as fully and as early as possible, to the environmental
implications arising from a proposal. This should ideally be undertaken prior
to the application for environmental authorization and/or the initiation of
any formal process of environmental assessment. Described here as pre-application
screening, this process should be initiated at the same time as any other
pre-feasibility type investigations (e.g. technical and financial studies).
Pre-application screening is the process by which key environmental
issues associated with a proposed development are anticipated at the earliest
opportunity, and are considered as an integral part of pre-feasibility investigations.
Here questions pertaining to the need for, and desirability of the proposal
must be considered, and issues such as technology and location alternatives
should be appraised at an appropriate level of detail. Significant environmental
impacts also have to be anticipated, and mitigation options accommodated in
initial development designs. It is a process that often takes the form of a
preliminary evaluation (described in section 2.3). In pre-application screening
the initiative for undertaking such a preliminary evaluation is taken by the
proponent
prior to an instruction by the lead authority or potential funding body to
do so.
An important aim of pre-application screening is to establish whether there
are aspects of a proposed development that are either technically flawed or
have the potential to give rise to significant or unacceptable environmental
consequences - the identification of potential 'fatal flaws'. Since the 'fatal
flaw' concept is quite subjective in terms of its definition, a brief discussion
of what it might constitute is required here.
1.1 Technical fatal flaw analysis
The technical aspects of a proposed development can be relatively easily reduced
to a form that makes it possible to objectively and quantitatively reveal potential
fatal flaws. For example, the technical feasibility of port construction can
be determined by environmental parameters such as the water depth, which can
be attained through dredging, and the consequent limitation that this imposes
on vessels expected to utilize the facility. Taking into account high dredging
costs, the presence of hard bedrock could constitute a technical fatal flaw,
which may result in the abandonment of the proposal.
1.2 Financial and economic fatal flaw analysis
For many large projects there are clearly costs and benefits beyond the consideration
of the financial investor. Many private infrastructure proposals give rise
to wider and longer-term social, economic and environmental impacts, which
do not appear in the private investor’s balance sheet. For example, a
financially viable project could give rise to negative externalities (such
as an increased number of respiratory diseases stemming from a decline in air
quality from industrial developments). If the cost of these externalities would
be factored in from the outset (for example, the cost of meeting the increased
demand for health services), a decision could be taken at an early stage -
and before significant extra costs are incurred - on whether or not the proposal
is viable in broader economic terms and over the long term. On the other hand,
a non-viable, short-term financial result could become a viable economic project
if positive externalities arise over the longer term (e.g. strong social and
developmental benefits).
These broader economic implications need to be borne in mind when determining
whether a proposal requires environmental assessment, and if so, what level
of assessment is appropriate.
Similar to the screening of technical issues, the screening of financial
and economic aspects of a proposed development is also reducible to a form
that can reveal fatal flaws generally on a quantitative (e.g. monetary) basis.
Ultimately the purpose of such an economic analysis is to make better investment
decisions, and to alert decision-makers, who are subject to a variety of conflicting
pressures, to the cost of economically suboptimal resource allocations as early
as possible in the proposal life cycle.
1.3 Ecological fatal flaw analysis
The assessment of ecological fatal flaws requires a significant departure
from the quantifiable mode of analysis according to which the technical, financial
and economic aspects associated with a proposed development are considered.
The assessment of ecological impacts tends to be an imprecise task and contains
a high level of predictive uncertainty. This uncertainty tends to increase
in the screening process as attempts are made to reduce the inherent complexity
of ecosystems in order to make a rapid preliminary evaluation of possible ecological
fatal flaws which would influence whether or not the proposal requires assessment,
and the level of assessment required.
Taking cognizance of these uncertainties, the focus of ecological fatal flaw
analysis should be directed at identifying and describing the ecological assets
of the target area - in particular those that are recognized to be of global
significance - and predicting the consequences of a proposal that will manifest
as irreversible/irreparable impacts on these assets. For example, irreversible
or irreparable impacts may include the extinction of species, and the elimination
of threatened habitat, which presents high levels of risk to the functional
integrity of the ecosystem extending beyond the immediate area in which a proposal
would be implemented.
Impact predictions that are made in the course of ecological fatal flaw analysis
generally involve a comparison between an anticipated impacted state and a
reference standard (e.g. the existing background state). A comparison can also
be made between an anticipated impacted state and thresholds at which species
or ecosystem functioning is expected to be jeopardized. The precautionary principle
should be adopted where there is uncertainty regarding the impact of a proposal
on ecosystems.
Pre-application screening thus aims to establish whether a proposed
development is flawed in terms of anticipated environmental impacts and whether
or not the proposal needs to be authorized by the lead authority. Preapplication
screening could therefore:
Eliminate the need for further environmental assessment, because the proposal
has been abandoned on the basis of the fatal flaw analysis.
Eliminate the need for further environmental assessment, because there
is certainty that the proposal will not require environmental authorization
to proceed.
Require adjustments to be made to the proposal prior to submission of the
application to the authorities to authorize the activity.
If there are no flaws that militate against advancing to the next phase of
the environmental assessment process, which is typically mandatory screening
(section 4.2), preapplication screening will have provided a good foundation
upon which mandatory screening and, possibly, environmental assessment, can
then proceed.
2. Mandatory screening
Mandatory screening is a process by which the anticipated environmental
consequences of a proposed development are considered, prior to the proposal
being authorized or rejected, to determine whether an environmental assessment
is required, and if so, the level of assessment
required.
The administration of this form of screening is usually the responsibility
of the lead authority tasked with the implementation of regulations or guidelines
pertaining to environmental assessment, or a funding body such as the World
Bank, which may require an environmental assessment prior to making the decision
on whether or not to assist with the financing of the proposal.
As a process, mandatory screening has the following key objectives:
T o classify development proposals in terms of the level of environmental
assessment required.
To ensure that only those proposals expected to potentially give rise
to environmental impacts of high significance are subjected to further environmental
assessment.
To expedite development approval where significant environmental impacts
associated with a proposed development are not anticipated.
The outcome of screening is the classification of a proposal in terms of
either 'no requirement' for further environmental assessment or a form of assessment
generally specified by the same set of regulations or guidelines that define
the requirements for screening. Typically four categories of classification
exist:
The proposal is expected to result in no significant environmental impacts
and further environmental assessment is not required, with the assumption
that there will be adherence to accepted environmental standards.
Certain environmental aspects of the proposal (including mitigation options)
are unclear and an environmental assessment, undertaken according to a specified
process, is required. The complexity of such an assessment will depend on
the circumstances that are pertinent to the proposed development.
The proposal will definitely give rise to significant impacts and will
automatically require a comprehensive environmental assessment.
The proposal is rejected on the basis of the significant environmental
impacts which exceed the defined thresholds of concern and which cannot be
mitigated.
There are several approaches that are used to classify development proposals
in the course of screening (Wood, 2000). The following approaches will be discussed
here:
Initial consultation.
Lists of actions/activities/projects and/or sensitive environments.
Preliminary evaluation.
Decision support systems.
Decision-maker's discretion.
In practice, screening will generally make use of a combination of these approaches.
2.1 Initial consultation
The screening process may begin with an initial consultation between the development
proponent and the decisionmaker (such as the lead authority or the funding
body), possibly with some form of involvement by key interested and affected
parties. The purpose of such consultation is to secure a first level of understanding
on the following:
The policy and legal aspects relating to environmental authorization;
i.e. the requirements of the national, regional or local environmental authorities
(or conceivably, a funding institution) responsible for authorizing the proposal.
The environment’s ability to satisfy the resource needs of the proposal,
as well as the potential for conflict between the proposal and the environment
(its biophysical, economic, social, cultural and political components).
The community requirements that have to be accommodated in the process
of environmental
assessment.
Any environmental issues that need immediate attention or investigation.
2.2 List-based approaches
Project or activity lists are often used in screening to specify developments
that automatically require environmental assessment. This approach directs
the process towards the environmental assessment of only those developments
that are classified as having the potential to result in significant environmental
impacts. By doing this, the number of applications for environmental authorization
is reduced and the load on institutions responsible for the administration
of the authorization process is eased.
Examples of developments that automatically require some process of environmental
assessment prior to possible authorization include the construction of nuclear
reactors, major dams, port developments, oil exploration and major industrial
developments. Listed activities might also include comparatively benign developments
that are unlikely to individually give rise to environmental impacts of high
significance, but which could result in significant cumulative environmental
impacts (e.g. structures required for telecommunication networks).
An approach to screening that complements the listing of where the location
of a proposed development in a listed sensitive environment triggers the requirement
for environmental assessment prior to possible authorization. Listed environments might
include national parks, wetlands, biodiversity hot spots, areas supporting
rare and endangered species, threatened habitats, areas particularly sensitive
to the effects of habitat fragmentation and environments highly valued for
the environmental services they deliver.
The above list-based approaches to screening may also be informed by specified
environmental thresholds, which, if not exceeded, may result in exemption from
the requirement for environmental assessment of a particular proposal. These
thresholds might, for example, relate to some specified limit in the size of
a development, its demand for environmental resources (e.g. water), its emissions
or the number of people it could affect.
The use of exclusion lists is a third list-based approach to screening
according to which there is an automatic rejection of projects applying for
authorization or funding, unless the proponent can justify exemption in this
regard. Proposals which may be included in exclusion lists are, for example,
production or activities involving harmful or exploitative forms of forced
labour or child labour, production or trade in weapons, or production or trade
in ozone-depleting substances subject to the international phasing out process.
Only if exemption is granted, will a decision be taken on the level on which
assessment is required.
2.3 Preliminary evaluation
An alternative to the list-based approach to screening is the requirement
for a preliminary evaluation in order to inform the decision to either exempt
a proposed development from a comprehensive environmental assessment, reject
the proposal or to define the level of further assessment that must precede
environmental authorization. A preliminary evaluation should:
D escribe the proposal and any alternatives that are being considered.
Describe how stakeholders will be consulted and how their concerns will
be taken into account.
Identify potential environmental issues.
2.4 Decision-maker's discretion
In contrast to the above examples of relatively wellstructured approaches
to screening, the screening process may also be conducted on a case-by-case
basis at the discretion of the lead authority or some other decisionmaker.
In this situation, screening may be undertaken by the decision-maker with or
without engaging other parties, such as a review committee or panels of experts.
Where there is discretionary decision-making, the ideal should be to strengthen
and broaden engagement in the review process, and thus increase the level of
objectivity and avoid what might be perceived as ad hoc or inconsistent decisions.
2.5 Decision support systems
In order to aid and streamline environmental decisionmaking, especially in
the case of routine development proposals, decision support systems may be
used either as an alternative or a supplement to other approaches to screening.
They may, for example, incorporate a scoring system based on a set of appraisal
criteria, which allows decision-makers to rapidly categorize proposals according
to these scores. Other more sophisticated decision support systems, including
computer-based systems, are typically encoded with expert knowledge to direct
the process of decision-making in a tightly structured manner (Canter and Sadler,
1997).
Having made the distinction between mandatory and pre-application screening,
it is clear that the various parties involved in screening have different responsibilities
and accountability in the process. Depending on the circumstances, screening
may be the responsibility of the development proponent, an institution such
as the national, provincial or local lead authority accountable for environmental
authorization, or a potential funding body. Responsibilities within the screening
process may also be assigned to other parties, such as a review panel or environmental
consultants, who may be tasked either to assist the development proponent or
the lead authority. These responsibilities are summarized in sections 1, 2
and 3 below.
1 Responsibility of the proponent
To ensure that proposals that might require environmental assessment are
submitted to the lead authority or other key decision-makers for screening.
To provide accurate and sufficiently detailed information on both the
proposed development and the affected environment in order to enable the
lead authority (or other decision-makers) to make an informed and responsible
decision on the need for further environmental assessment.
2 Responsibility of the decision-maker
To ensure that applications for environmental authorization or funding
are correctly processed with minimum delay.
To ensure that the proponent provides sufficient information upon which
a decision can be made concerning the immediate authorization or rejection
of the application, or the need for further environmental assessment.
To request additional information if insufficient information is provided
by the project proponent.
To ensure that all environmental considerations, including social, biophysical
and economic issues, are taken into account in the decision-making process.
To adopt an impartial and transparent screening process, which includes
the right to appeal the decisions made.
3 Responsibility of the consultant
To inform the proponent on the legal requirements for environmental assessment
and best practices for pre-application or mandatory screening.
To assist the proponent or the lead authority in fulfilling their respective
screening responsibilities, either through the generation or the interpretation
of project and environmental information.
The screening process aims to provide sufficient information on a proposed
development and the environment for a decision to be made on the need for,
and level of environmental assessment.
The collation of information for the screening process may involve some preliminary
engagement with
stakeholders, the consideration of development alternatives, the identification
of key issues, consideration of specialist expertise, preliminary assessment
of possible impacts, the assignment of impact significance, consideration of
mitigation options, and reporting of preliminary environmental information.
However, although these information requirements are similar to those typically
associated with an environmental assessment, screening should not be confused
with full environmental assessment. The difference lies in the level of detail
expected of screening versus that required of a full environmental assessment.
The information required for the screening process is of a far more qualitative,
superficial and preliminary nature than that required of a full environmental
assessment.
Examples of the type of information that may be required to inform the process
of environmental screening are presented in Box 2.
Box 2: Examples of the Type of Information required during the Screening
Development Proposals
Description of the proposal and the receiving environment
A development proposal submitted for screening should document, in brief:
The name of proponent.
Relevant background information about the proponent.
A description of what is proposed.
The need for the proposal.
Types of processes that might be used (e.g. technical
processes, means of transport, approaches to training and capacity-building,
approaches to stakeholder engagement).
The sources and quantities of raw material and
supplies required.
Possible new infrastructure/social service requirements
(e.g. power, water supply, housing, transport, education, hospital).
The source of funding.
A summary of planning or other investigations
already undertaken.
Relevant policies, laws or guidelines.
An indication of how the proposal fits into any
wider programme or policy.
The timing of implementation/construction and
initial operations.
The expected life of the proposal.
A description of the receiving environment, including
the biophysical, social and economic components (e.g. air and water
quality, demographics, literacy levels, economic activities).
An initial indication of the proposal’s
potential environmental impacts (e.g. waste generation, human health
impacts, noise, employment opportunities).
An indication of any feasible or prudent alternative(s)
to the proposal.
1 Screening practices in developing countries and countries in transition
The approach to screening varies between countries that practice environmental
assessment. In South Africa screening is part of the regulated approach to
environmental impact assessment (EIA), but it is described as the "application
for authorization to undertake an activity" rather than screening per se (DEAT,
1998).
Screening in other African countries such as Tunisia, Turkey and Egypt is
largely based on screening lists that define whether development proposals
require preliminary assessment or a full EIA (George, 2000). Elsewhere in Africa,
where EIA regulations are not yet promulgated, the screening process is generally
defined according to criteria developed by funding agencies (e.g. the World
Bank) or built into industry best practice approaches to EIAs. For example,
licensing agreements between the governments of Angola and Cameroon and international
oil companies include the requirement for an EIA even though national regulations
have yet to be promulgated.
Some countries in the Asia-Pacific region, such as Taiwan, have developed
screening systems that take into account the specific characteristics of individual
projects. However, since this approach to screening generally requires a high
level of expertise from the administering authority, it is inappropriate for
application in countries within the region where such administrative competence
does not yet exist. Here, the previously described approach to screening based
on listed activities and listed environments is more typically applied. The
procedure in India, for example, establishes the need for further environmental
assessment through reference to listed project types and threshold criteria
(some expressed in terms of project costs), where the outcome of screening
distinguishes between a "rapid" or "full EIA" (George, 2000). In Nepal, the
screening system allows for an initial environmental examination, which may
subsequently lead to a full EIA.
In former Soviet countries, which have maintained the state environmental
review as the equivalent process to EIA, there is no formal screening phase
in the environmental authorization of proposed developments. All development
activities requiring planning approval are subject to state environmental review,
which is conducted by the state environmental authority or a committee established
by this authority. Here the need for, and approach to environmental assessment
is based on authority discretion, which typically results in the exemption
of a range of developments from environmental assessment (George, 2000).
Most South American countries apply screening based on listed project types
that require EIA. In Brazil and Mexico these lists also define whether environmental
decisionmaking is vested with the provincial or national authority. Screening
in a country such as Venezuela takes into account whether or not a proposed
development is located in a sensitive environment.
In general, the screening process in countries where environmental assessment
is least developed will often be based on the discretion of a government authority.
Such discretion might be exercised by a senior official, an appointed committee
or, in the case of several countries in sub-Saharan Africa, the head of state.
Even in the case of countries with well-developed systems for environmental
assessment, there is a degree of discretion built into the screening procedure.
However, most countries base their screening on activity or environmental sensitivity
lists. This approach curtails the degree of discretion and flexibility that
is exercised by an environmental authority in determining whether or not a
proposal should be submitted for environmental assessment (George, 2000).
2 Challenges and short-comings of screening practice
One of the fundamental problems associated with the screening process is the
lack of capacity by the environmental authority or decision-making body to
undertake effective and adequate screening. This problem is exacerbated where
screening approaches are inappropriate or flawed. In developing countries the
use of imported screening methodologies may be too complex and or inappropriate
to be applied effectively (Biswas, as cited in Wood, 2000). Further problems
arise when the
screening requirements of the national government vary from those of international
funding agencies (Wood, 2000).
A shortcoming of project or activity lists is that projects of the same general
type of activity may vary greatly in size, plant requirements, process and
layout and, therefore, in their impact on the environment (Jones, 1999). This
essentially limits the effectiveness of lists that do not include some environmental
threshold to screen out proposals that do not require environmental assessment.
Without these thresholds, lists merely add to the administrative burden of
the decision-maker. Where resources are insufficient to handle the large volume
of applications, the risk increases that proposals that might have a significant
impact may be overlooked and approved without adequate environmental safeguards
attached to the development authorization.
On the other hand, the designation of thresholds is not without problems,
and these tend to be associated with the difficulty of determining impact significance.
For example, a threshold for housing developments requiring environmental assessment
may be set at 100 residential units; however, there is clearly little difference
in the impact significance of 99 units - the development of which may not require
environmental assessment. This procedural weakness may encourage development
proponents to formulate proposals that fall just below the threshold requiring
environmental assessment. The combined or cumulative effect of authorizing
a number of such proposals
is thus overlooked.
All too often there is not a clear distinction between screening, scoping
and the assessment of environmental impacts. This threatens to undermine the
entire environmental assessment process as proponents attempt to avoid undertaking
a full environmental assessment by adding more information than is necessary
into the screening phase. This mini assessment is generally undertaken with
little or no prior engagement with stakeholders, and poses the risk that key
issues may be overlooked as incorrect assumptions are made regarding the concerns
of affected stakeholders regarding the
proposal.
A poor screening process may lead to incorrect decisions concerning whether
a proposed development should be authorized without further study or whether
a full environmental assessment should be undertaken to inform decision-making.
The lack of universally accepted criteria to determine the significance of
impacts makes it impossible to guarantee cons istency in decision-making.
Screening plays an important role in IEM by determining whether or not a proposal
requires environmental assessment, and if so, what level of assessment is appropriate.
There is, however, a need to ensure that screening remains clearly differentiated
from scoping and from a full environmental assessment in order to reduce the
burden on administrators and to improve the effectiveness and efficiency of
the environmental assessment process. For similar reasons, pre-application
screening by proponents should be encouraged.
Canter, L.W. and Sadler, B. (1997) A Tool Kit for Effective EIA Practice
- Review of Methods and Perspectives on their Application, A supplementary
report of the International Study of the Effectiveness of Environmental Assessment,
International Association for Impact Assessment.
DEAT (1998) Environmental Impact Management Guideline Document: EIA Regulations
- Implementation of Sections 21, 22 and 26 of the Environment Conservation
Act, Department of Environmental Affairs and Tourism, Pretoria, South
Africa.
DWAF (2001) Generic Public Participation Guidelines, Department of
Water Affairs and Forestry, Pretoria, South Africa.
George, C. (2000) Comparative review of environmental assessment procedures
and practice, In: Lee, N. and George, C. (eds), Environmental Assessment
in Developing and Transitional Countries, John Wiley and Sons (Ltd), 35-68
pp.
Glavovic, B., Shandler, D. & Abrahams, D. (2001) Discussion Document
Towards a Policy for Public Participation in Spatial Planning, City
of Cape Town, CMC Administration: Spatial Planning Department; Planning,
Environment and Housing Directorate, South Africa.
Haug, P.T, Burwel R.W, Stein, A, & Bandurski, B.L. (1994) Determining
the Significance of Environmental Issues Under the National Environmental Policy
Act, Journal of Environmental Management 18 (1), 15-24.
IAIA and IEA (1999) Principles of Environmental Impact Assessment Best
Practice. http://www.iaia.org
IFC (1998) International Finance Corporation Operational Policies:
OP 4.10, Environmental Assessment. http://www.ifc.org/enviro
Jones, C.E. (1999) Screening, Scoping and Consideration of Alternatives, In:
J. Petts (Ed.) Handbook of Environmental Impact Assessment, Vol. 1: Environmental
Impact Assessment: Process, Methods and Potential, Oxford: Blackwell Science,
201-228 pp.
Preston, G.R., Robins, N. and Fuggle, R.F. (1992) Integrated Environmental
Management, In: Fuggle, R.F. and Rabie, M.A. (eds), Environmental Management
in South Africa, Juta and Co. Ltd.
Sadler, B. (1996) Environmental Assessment in a Changing World: Evaluating
Practice to Improve Performance, Final report of the international study
of the effectiveness of environmental assessment, International Association
for Impact Assessment, Canadian Environmental Assessment Agency, Ottawa,
Canada.
UNEP (1996) The Environmental Impact Assessment Training Resource Manual:
Preliminary Version, June 1996, United Nations Environment Programme.
Wood, C. (2000) Screening and scoping, In: Lee. N. & George, C. (eds)
Environmental Assessment in Developing and Transitional Countries. John Wiley
and Sons (Ltd). 71-83 pp.
Those part s of the socio-economic and biophysical environment affected by
the development.
Affected public
Groups, organizations and/or individuals who believe that an action might
affect them.
Alternative proposal
A possible course of action, in place of another, that would meet the same
purpose and need. Alternative proposals can refer to any of the following,
but are not necessarily limited to these:
Alternative sites for development.
Alternative projects for a particular site.
Alternative site layouts.
Alternative designs.
Alternative processes.
Alternative materials
In IEM the so-called "no-go" alternative also requires investigation.
Authorities
The national, provincial or local authorities that have a decision-making
role or interest in the proposal or activity. The term includes the lead authority,
as well as other authorities.
Baseline
Conditions that currently exist. Also called “existing conditions.”
Baseline information
Information derived from data that:
Record the existing elements and trends in the environment.
Record the characteristics of a given project proposal.
Decision-maker
The person(s) entrusted with the responsibility for allocating resources or
granting approval to a proposal.
Decision-making
The sequence of steps, actions or procedures that result in decisions, at any
stage of a proposal.
Environment
The surroundings within which humans exist and that are made up of:
i. the land, water and atmosphere of the earth;
ii. micro-organisms, plant and animal life;
iii. any part or combination of (i) and (ii) and the interrelationships among
and between them; and
iv. the physical, chemical, aesthetic and cultural properties and conditions
of the foregoing that influence human health and well-being. This includes
the economic, cultural, historical, and political circumstances, conditions
and objects that affect the existence and development of an individual, organism
or group.
Environmental Assessment (EA)
The generic term for all forms of environmental assessment for projects, plans,
programmes or policies. This includes methods/tools such as EIA, strategic
environmental assessment, sustainability assessment and risk assessment.
Environmental consultant
Individuals or firms that act in an independent and unbiased manner to provide
information for decision-making.
Environmental Impact Assessment (EIA)
A public process that is used to identify, predict and assess the potential
impact of a proposed project on the environment. The EIA is used to inform
decision-making.
Fatal flaw
Any problem, issue or conflict (real or perceived) that could result in proposals
being rejected or stopped.
Impact
The positive or negative effects on human well-being and/or the environment.
Integrated Environmental Management (IEM)
A philosophy that prescribes a code of practice for ensuring that environmental
considerations are fully integrated into all stages of the development and
decision-making process. The IEM philosophy (and principles) is interpreted
as applying to the planning, assessment, implementation and management of any
proposal (project, plan, programme or policy) or activity - at local, national
and international level - that has a potentially significant effect on the
environment. Implementation of this philosophy relies on the selection and
application of appropriate tools for a particular proposal or activity. These
may include environmental assessment tools (such as strategic environmental
assessment and risk assessment), environmental management tools (such as monitoring,
auditing and reporting) and decision-making tools (such as multi-criteria decision
support systems or advisory councils).
Interested and affected parties (I and APs)
Individuals, communities or groups, other than the proponent or the authorities,
whose interests may be positively or negatively affected by a proposal or activity
and/or who are concerned with a proposal or activity and its consequences.
These may include local communities, investors, business associations, trade
unions, customers, consumers and environmental interest groups. The principle
that environmental consultants and stakeholder engagement practitioners should
be independent and unbiased excludes these groups from being cons idered stakeholders
.
Lead authority
The environmental authority at the national, provincial or local level entrusted,
in terms of legislation, with the responsibility of granting approval to a
proposal or allocating resources and of directing or coordinating the assessment
of a proposal that affects a number of authorities.
Mitigate
The implementation of practical measures to reduce the adverse effects or
enhance the beneficial effects of an action.
Non-governmental organizations (NGOs)
Voluntary environmental, social, labour or community organizations, charities
or pressure groups.
Proponent
Any individual, government department, authority, industry or association
proposing an activity (e.g. project, programme or policy).
Proposal
The development of a project, plan, programme or policy. Proposals can refer
to new initiatives or extensions to, and revisions of existing ones.
Public
Ordinary citizens who have diverse cultural, educational, political and socio-economic
characteristics. The public is not a homogeneous and unified group of people
with a set of agreed common interests and aims. There is no single public.
There are a number of publics who may emerge at any time during the process,
depending on their particular concerns and the issues involved.
Roleplayers
The stakeholders who play a role in the environmental decision-making process.
This role is determined by the level of engagement and the objectives set at
the outset of the process.
Scoping
The process of determining the spatial and temporal boundaries (i.e. extent)
and key issues to be addressed in an environmental assessment. The main purpose
of scoping is to focus the environmental assessment on a manageable number
of important questions. Scoping should also ensure that only significant issues
and reasonable alternatives are examined.
Screening
A decision-making process to determine whether or not a development proposal
requires environmental assessment, and if so, what level of assessment is
appropriate. Screening is initiated during the early stages of the development
of a proposal.
Significant/significance
Significance can be differentiated into impact magnitude and impact significance.
Impact magnitude is the measurable change (i.e. intensity, duration and likelihood).
Impact significance is the value placed on the change by different affected
parties (i.e. level of significance and acceptability). It is an anthropocentric
concept, which makes use of value judgements and science-based criteria (i.e.
biophysical, social and economic). Such judgement reflects the political reality
of impact assessment in which significance is translated into public acceptability
of impacts.
Stakeholders
A subgroup of the public whose interests may be positively or negatively affected
by a proposal or activity and/or who are concerned with a proposal or activity
and its consequences. The term therefore includes the proponent, authorities
(both the lead authority and other authorities) and all interested and affected
parties (I&APs). The principle that environmental consultants and stakeholder
engagement practitioners should be independent and unbiased excludes these
groups from being considered stakeholders.
Stakeholder engagement
The process of engagement between stakeholders (the proponent, authorities
and I&APs) during the planning, assessment, implementation and/or management
of proposals or activities. The level of stakeholder engagement varies, depending
on the nature of the proposal or activity and the level of commitment by stakeholders
to the process. Stakeholder engagement can therefore be described by a spectrum
or continuum of increasing levels of engagement in the decisionmaking process.
The term is considered to be more appropriate than the term “public participation”.
Stakeholder engagement practitioner
Individuals or firms whose role is to act as independent, objective facilitators,
mediators, conciliators or arbitrators in the stakeholder engagement process.
The principle of independence and objectivity excludes stakeholder engagement
practitioners from being considered stakeholders.
