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2. Screening of projects, preliminary assessment of environmental impact and other regulatory options

2.1 Screening of the project
2.2 Preliminary assessment of environmental impact
2.3 Design revision and phased environmental analysis

The procedure suggested by the present Guidelines for assessing, and eventually controlling, environmental impacts is one of stop-wise progression in formality and complexity. As foreseen, the progression from one step to the next, if any, is determined by the relative severity or importance of the impacts predicted at each step. In general, the intent of the procedure is to keep the means for assessing or controlling environmental impacts as simple and informal as possible. Resort to formal and complex stops should be dictated only be compelling circumstances.

The steps foreseen include (a) Screening of the Project; (b) Preliminary Assessment of Environmental Impact; (c) Design Revision and Phased Environmental Analysis; and (d) Detailed, or Formal, Environmental Impact Assessment. Detailed Assessment is described separately in Chapter 3.

2.1 Screening of the project

At the time a forestry project is first defined? the first - and in some case, the last - step proposed for assessing environmental impact is a screening of the project from an environmental point of view.

This screening would normally consist of a meeting between planner(s) of the forestry project and relevant government officials (environmental protection, natural resources, public health, social affairs, etc.). At this meeting, the likely biophysical and socio-economic impacts of the project would be discussed and further regulatory steps, if any, would be decided. Depending on the circumstances, the meeting could be attended by independent experts, for example, wildlife experts from a university or research centre if the forestry project happens to be in or near a particularly sensitive wildlife area.

The screening might take the form of a run-through of a list of potential impacts, such as the ones provided in Appendix I, II and III of those Guidelines. At this stage, Appendix I, the Checklist for the Preliminary Assessment of Environmental Impact (cf. Section 2.2 below) would be used simply as an aide-mémoire, primarily for the items listed under "Aspect Liable to be Modified or New Structures or Institutions".

The outcome of the screening, that is the consensus reached, would ordinarily be stated in the initial project plan (in the case of UNDP/FAO, a paragraph under "Special Considerations" in the Project Document). The statement would be to the effect that either:

(a) the project proposed has no likely harmful impact (for example a survey of forest resources or a small experimental plantation), and no further environmental action is required (other than routine environmental precaution during execution of the project, such as avoiding undue disturbance of wildlife in the course of inventorying forest resources);

(b) certain environmental aspects of the project (including mitigative methods) are poorly known or unknown, and a more systematic assessment is needed by means of a Preliminary Assessment of Impact (Sec. 2.2 below);

(c) the project has one or several specific impacts, but these impacts can be prevented or mitigated by moans of a revision of the project design, or by means of an environmental monitoring programme phased over the implementation of the project (Sec. 2.3 below);

(d) the project is in such an environmentally sensitive area, has an inevitable massive impact, or fails to maximize benefits that a detailed, formal assessment of impact is required (Chapter 3); detailed assessment is designed primarily to consider alternative sites or development methods, and to weigh more accurately socio-economic benefits against environmental losses.

These various steps are summarized in Figure 1.

Figure 1 Suggested Procedure for the Assessment of the Environmental Impact of Forestry Projects

A procedural option is to let planners of forestry projects, sufficiently familiar with the project area or knowledgeable about environmental matters, conduct their own environmental screening of the project. These self-evaluation would then be submitted to the relevant government agencies, which would rule on further regulatory action, if any.

Environmental self-evaluations by proponents obviously carry a risk of conflict of interests. A further drawback is that independent screening fails to involve host-country regulatory agencies as early as possible in the environmental planning of projects. In general, it is desirable that environmental problems be identified by all parties as early as possible in the planning of projects, and that attempts be made to solve these problems while the project design is still fluid. The aims of environmental protection, and of project planning in general, are poorly served by disagreements or confrontations between proponents and regulatory agencies at late stages of planning or at the time permits are being issued.

2.2 Preliminary assessment of environmental impact

2.2.1 Data base and familiarization with the project area
2.2.2 Preparation of the Checklist
2.2.3 Administrative follow-up

If the initial screening of a project has deemed a Preliminary Assessment of Environmental Impact necessary, further planning of the project should include this Assessment, and eventually take its recommendations into account. Further decisions concerning the execution of the project should then be based on the review of the Preliminary Assessment by host-country regulatory agencies, possibly in consultation with the proponent and the funding agency(ies). In general, effective environmental planning and control will require a mix of regulatory action, the goodwill of proponents, and the requirement on the part of funding agencies that proper environmental safeguards be built into forestry projects.

2.2.1 Data base and familiarization with the project area

In preparation for preliminary assessment, the assessor(s)¹ should assemble all available information and familiarize himself (themselves) with the environment of the project area. To these ends, the following steps may be found useful:

1 The question of who prepares impact reports is discussed in Chapter 3, Sec. 3.2.

(1) The forestry project being assessed should be examined in relation to other past, present or foreseeable development projects in the basin, region or other pertinent geographical area in order to evaluate possible cumulative impacts;

(2) The forestry project should be placed in the context of regional or national land-use planning, if such exists;

(3) The project should be examined in relation to existing, planned or potential conservation areas (parks, nature reserves, game refuges, protection forests); specifically, the distances and types of habitats between the project area and the conservation areas should be determined with a view to assessing the potential indirect impact of the project on these areas;

(4) Basic environmental information such as soils, vegetation, geologic or hydrologic maps, if available, should be obtained from government agencies, research centres universities or technical assistance programmes (cf. Annex C). This information can be used directly (eg., highly erodible soils to be avoided; cf. Bole, 1978) or can be interpreted (eg., geologic maps, primarily unusual geology, can be used as guides to floristic diversity or uniqueness in the absence of direct botanical data);

(5) Regional or national floras, especially clasifications of vegetation for conservation purposes, and general guides to the fauna and its preferred habitats should be consulted so as to place the project area in its broad ecological context (cf. Annex B);

(6) If available, national registers of rare, endangered or protected plant and animal species should be consulted so as to gauge the likely presence of any of these species in the project area; it should be borne in mind that those registers may not be compete or up to date, especially in the humid tropics where many species are still unknown to science (cf. Appendix V);

(7) World conservation publications such as the IUCN Species Monitoring data books should be consulted for the reasons given under (6) above;

(8) A special effort should be made to consult the local population for information and opinions, especially regarding traditional resource use and other aspects of the local economy as well as social values and aspirations; local residents may also know much about animals and their habit ate and the informal taxonomy of the vegetation; consultation also serves, to establish good local relations;

(9) Existing guidelines concerning logging methods road construction, erosion control and other forms of environmental protection (cf. Annex B) should be consulted, particularly their recommendations concerning terrain to be avoided;

(10) Existing environmental legislation and regulations (as well as international conventions signed by the particular county) should be examined so as to ensure that the project meets, as a minimum statutory or regulatory standards;

(11) Existing literature on the project area or region, including prior impact reports should be consulted for any information that may facilitate the prediction of impacts

(12) Regional, national or international research centres or data banks should be contacted, if necessary, for the purpose of obtaining data and opinions concerning the environment in the project area and its relative sensitivity to disturbance (cf. Annex C);

(13) Whatever possible, a map should be prepared outlining major habitats in and near the project area, using information obtained from local residents and research centres from ground and aerial reconnaissance surveys of the main terrain and vegetation types, and from existing topographic geologic vegetation and other maps; in areas whore the vegetation and the habitat preferences of key animal species are reasonably well known, potential habitats of particular species can also be outlined; this map, which can be prepared directly on aerial photographs, serves not only as an aid to impact assessment but also as a briefing document in discussions with regulatory or other agencies.

2.2.2 Preparation of the Checklist

Preparation of the Checklist for Preliminary Assessment of Environmental Impact (Appendix I) requires reasonable familiarity with the project area, as acquired in part on the basis of the steps listed above. There is, of course, no substitute for as much field work in the proposed project area as is feasible; failing this, assessment may have to rely to a considerable degree on remote sensing primarily air photo- interpretation. Another technique that can be used to evaluate the project area is overflight by experts on the vegetation, animal ecology, traditional land use or other environmental components of the particular region. Consultation with regional or national research centres (cf. Annex C) should reveal if such experts are available for a particular region.

The Checklist is structured primarily on the basis of environmental components in the case of the biophysical environment, and of socio-economic concerns in the case of activities, man-made structures, institutions or demographic-economic changes brought about or needed by a forestry project. For each of these components or concerns, specific aspects are listed that are liable to be modified by forestry activities (eg., a stream made turbid), or that represent changes or new structures attributable to a forestry project (eg., logging camps, new settlements). Potential impacts of forestry projects, listed by both environmental components and by individual forestry activities, are given in Appendixes II and III.

Magnitude of Impacts. For each foreseeable impact, the Checklist requires first a judgment concerning the magnitude, that is basically the size of the impact. Size and the social importance of an impact are not necessarily the same. A statement concerning magnitude is required so that the reviewer of the preliminary assessment can judge for himself whether the evaluations of importance made by the assessor are reasonable.

Because the primary purpose of impact assessment is to assist decision-making, and decisions are usually required only when "major" and socially "important" impact is predicted, a key judgement needed for the Checklist is what Constitutes "major" impact. As with other aspects of EIA, subjectivity is inevitable but also desirable: the decision between "insignificant", "minor" or "major" impact must rest on a knowledge of local conditions, on the relative scale of local phenomena and on shifting priorities and values. Appendix IV does, however, suggest some thresholds of impact that can be used to judge whether or not to record "major" impact in a particular setting.

The magnitude of impacts can be recorded by means of checkmarks (ticks). However, in order to facilitate visual presentation or rapid scanning of documents, it may be advantageous to record different levels of impacts by mesas of different symbols or colours, with "major" impacts mode especially conspicuous. "Don't know" written across the three columns under Magnitude should also be an acceptable entry, for the reasons given below.

An alternative is to record the magnitude of impacts by means of minus or plus signs so as to convoy immediately the negative or positive nature of the impacts. However, the Checklist is designed basically so that final value judgements concerning the not long-term impact are made under Importance of Impacts.

Nature of Impacts. The recording of the type, duration, and extent of impacts is largely self-explanatory, but again in some cases difficult judgements may be required for which local experience is irreplaceable. In the case of some items (eg., the duration and reversibility of nutrient losses or alterations of soil micro-organismic life), the entry "don't know" may be the only realistic one given the present state of knowledge of certain phenomena. However, the Checklist serves a useful function if it calls attention to important but poorly known aspects of forestry. In addition, the entry "don't know" may help to set research priorities in a region where impact reports repeatedly carry this entry opposite a particular environmental aspect.

The local or regional extent of an impact is basically an elaboration of the magnitude of the impact. However, it is possible to have a "minor" impact which is "regional" in extent: an example might be light selective cutting over a large area.

Transboundary impacts should be noted because, e van if they are "minor", they can cause legal or political problems.

Perhaps one of the most useful functions of EIA is to draw attention to indirect effects, or environmental changes not immediately or directly related to the forestry activities being proposed. Thus, for example, a forestry project may have as a direct effect the removal of a certain area of forest and the creation of a certain number of jobs, but it may also displace herbivores from the former forest to agricultural lance and expose bodies of water that may become breeding areas for malaria mosquitoes. Appendixes II and III list several indirect effects of forestry. Indirect impacts should be explained briefly in the Remarks section of the Checklist, as they may not be obvious.

The Remarks section of the Checklist should be used mainly to help identify the impacts, such as by naming the species affected, the social benefits generated, or visual changes foreseen. Causal relationships affecting more than one aspect simultaneously, feedback relationships (eg., new browse may increase the number of herbivores, but also make them more vulnerable to hunting) and any other impacts that need to be qualified should also be described briefly under Remarks.

Importance of Impacts. The critical section of the Checklist concerns the social importance of the impacts, whether positive or negative. Because some impacts ma y be detrimental in the short term but positive in the long run or vice versa it is suggested that the social importance noted on the Checklist be that of the net or residual long-term impact. This is the ultimate impact for the foreseeable future, as determined after taking into account the initial fluctuations and, depending on circumstances, mitigation. The question of mitigation is discussed further below under Mitigated vs. Unmitigated Impact.

The assessment of the social importance of impacts requires more than any other aspect of EIA, mature judgement and familiarity with a particular ecological and socioeconomic context. For example, impacts on a forest habitat that would normally be considered "unimportant" may have to be judged "important" if they happen to disrupt habitat continuity between two game reserves, or if these impacts will occur in the buffer zone around a national park. Similarly, otherwise "minor" impacts that happen to affect territories across a national boundary may have to be recorded as "important" because of potential political repercussions.

In general, it is recommended that persons preparing the Checklist reach a consensus1 as soon as possible with regulatory agencies, local residents, and with the scientific community as to what Constitutes "important" impacts in a particular setting. No one assessor can be expected to pass informed judgements on all aspects of the environment. In EIA, it is also essential to avoid disagreements over basic definitions and value judgements at the review stage, as at that stage time and energy usually have to be devoted to such issues as the accuracy or reliability of impact predictions and choices concerning alternatives or mitigation.

1 A consensus own often be reached in simple discussions among interested parties. A more formal technique that can be used to obtain a consensus over issues as subjective as the social importance of impacts is the so-called Delphi method. A summary of this method is given in Sec. 3.3.2 of these Guidelines.

The importance of impacts can be recorded on a scale of 1 to 5 (or 1 to 10, if more subtle differentiations are feasible or desirable), whether positive or negative, with 5 (or 10) representing "very important" and 1 "negligible". Again, "don't know" should be an acceptable entry.

Mitigated vs. Unmitigated Impacts. Two basic options are available for recording impacts. One option is to record so-galled "raw" impacts, or impacts that have not been reduced by mitigation. The rationale for this option is as follows:

(1) The prediction of impacts is often tentative or speculative; if then mitigation is assumed and "built" into the impacts recorded, the latter become even more tentative or speculative;

(2) Impacts are more likely to occur than mitigation, as impacts are often a matter of well-established phenomena such as leaching of exposed soils, reproductive stress through crowding, gravity failures and} the like. In contrast, mitigation often depends on such imponderables as goodwill, enforcement of environmental laws, availability of funds, and technical competence. Thus, one issue (impact prediction with all its uncertainties) should not be further clouded by fusing it with another issue (possible mitigation). There is also a time factor, as even with the best of intentions, mitigation often lags behind the occurrence of impacts. Irreversible damage can thus occur in the meantime.

For these reasons, some decision-makers prefer to be presented with statements of impacts as are likely to occur without the intervention of remedial or preventive action. It is then up to the decision-makers to judge, in the light of possible mitigation, whether certain impacts are socially acceptable. This assumes, of course, that decision-makers are familiar with techniques of mitigation.

If the decision is made to record raw or unmitigated impacts, the Checklist should carry a statement to that effect. The Remarks section of the Checklist can then be used to indicate which techniques if any, are available to prevent or reduce a particular impact.

The second option is to record impacts as reduced by mitigation (so-called "residual" impacts). In jurisdictions where preventive or remedial measures are reasonably well known and routinely applied, this second option is usually followed.

A further option might be to record the magnitude and nature of impacts as they might occur without mitigation, but to assess the social importance of impacts on the assumption the impacts have been reduced by mitigation. The mitigative measures would be noted in the Remarks section of the Checklist.

The important consideration is to make clear, either on the Checklist itself or in an accompanying statement, which type of impacts has been recorded and what assumptions have been made Concerning mitigation.

Alternatives. It is foreseen that preliminary assessment would normally be carried out for only one proposed project area. One purpose of preliminary assessment is, in fact, to determine whether certain impacts are sufficiently severe that alternative areas (or development methods or schedules) must be examined by means of a design revision or of a detailed impact report.

If preliminary assessment shows that the overall impact is minor, then alternatives need not be considered. On the other hand, the initial screening of the project may require that preliminary assessment be carried out for a number of project areas? and that the completed Checklists be compared for relative impact.

2.2.3 Administrative follow-up

The completed Checklist would be accompanied by a statement that recommends either a) no further environmental action other than routine environmental protection during the implementation of the forestry project; b) further environmental action, as specified on the basis of the findings of preliminary assessment.

It is suggested that a -3 to -5 rating ("important" to "very important" negative impact) for a particular aspect of the environment be grounds for considering a design revision or phased environmental analysis, as described below This assumes that the environmental problem(s) is (are) well identified and remedial measures are known

If the problem(s) is (are) poorly identified or more information is needed, then a full or partial detailed assessment (Chapter 3) may be required. A partial detailed impact report might he prescribed in those cases where it is clear that the likely problems are only in one sector of the environment. An example might be wildlife in an area that is essentially uninhabited by man, where soil erosion is unlikely, and where the vegetation has no unusual scientific or aesthetic value.

If preliminary assessment reveals massive impact, then a detailed impact report may be required, primarily for the purpose of considering alternative project areas. In case a detailed impact report is called for, the statement accompanying the Checklist should also drew attention to foreseeable major date gape so as to alert regulatory and other government agencies as early as possible to the need to collect field data.

In general, the statement accompanying the Checklist should attempt to define as much as possible the nature and scope of the detailed impact report required. Regulatory agencies may, of course, exercise further guidance by issuing specific terms of reference for the detailed impact report shown to be necessary by preliminary assessment. Practice has indeed shown that, whenever a formal, detailed impact report is needed, regulatory agencies often issue terms of reference designed to ensure that the report emphasizes certain issues.

2.3 Design revision and phased environmental analysis

2.3.1 Design revision
2.3.2 Phased environmental analysis

Initial screening or preliminary assessment of the environmental impact of a project may recommend, as the final environmental action, either a revision of the project design, or an environmental analysis phased over the duration of the project and possibly some time thereafter. A combination of the two is also possible. The administrative outcome of detailed EIA (cf. Chapter 3) may, likewise, be a design revision or a phased environmental analysis.

2.3.1 Design revision

The revision of the project design may consist of binding prescriptions concerning preventive or mitigative measures to be incorporated into a new design. These measures may include, for example, different design criteria for forest roads and culverts or different logging methods. Preventive measures may be the omission of certain parts of the original project design that are considered too environmentally costly. Revision of the project may also consist of revised scheduling of the project, such as postponing certain activities beyond the season of maximum-intensity rainfall, or after a certain area has been investigated by wildlife specialists and certain animals relocated.

Other forms of project revision may be the obligation to redesign certain aspects of the project in collaboration with environmental specialists seconded from government agencies or from a designated research institute. A proponent could also be asked to revise 0a project in strict accordance with specified operational handbooks concerning road construction erosion control, log hauling, foiling methods and the like.

A project revision may also be the requirement to consider alternative altos or areas until certain specified impacts are minimized or avoided, or certain benefits (such as job creation) are maximised. Such a requirement as, carry with it the obligation to integrate certain government or other specialists into the project design team.

2.3.2 Phased environmental analysis

The approval of a forestry project may be made Conditional on the execution of certain environmental analyses, including remedial measures, during certain phased of the project or even after the project has ended. A Conditional approval should specify in detail (a) the reasons for the sequential analyses requested; (b) the type and timing of the analyses required; (c) who will perform the analyses and for which regulatory agency ion); (d) financial arrangements, if any.

For example, the approval of a forestry project may specify that, immediately prior to logging, a primate specialist seconded from research institute X examine the project area and take whatever measures are necessary to protect or relocate species Y and Z witch happen to be protected by law. This specialist would then inform the appropriate government agency that this action has taken place and the logging can proceed. Another condition might be that, during logging, certain streams in the project be monitored at specified intervals for excessive sedimentation. If such sedimentation is detected and a clear threat to fishery exists, then project management must moot with the agency responsible for fisheries to discuss mitigative measures, including a revision of logging or log-hauling methods.

Phased environmental analysis might also include post-development remedial work and monitoring of the recovery of certain environmental elements. These elements could be the regeneration of useful tree species or the re-establishment of fisheries in aquatics habitats disturbed by logging. There could be certain financial conditions such as payment for rehabilitation, attached to findings of poor or no recovery.

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